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Home My WebLink About941078.tiff RESOLUTION RE: APPROVE SITE SPECIFIC DEVELOPMENT PLAN AND SPECIAL REVIEW PERMIT #1039 FOR AN INJECTION WELL FOR DISPOSAL OF CLASS I AND CLASS II LIQUID WASTE AS DEFINED IN THE CODE OF FEDERAL REGULATIONS (40 CFR 144.6) - WRIGHT'S DISPOSAL, INC. WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, the Board of County Commissioners held a public hearing on the 2nd day of November, 1994, at the hour of 10:00 a.m. in the Chambers of the Board for the purpose of hearing the application of Wright's Disposal, Inc., 2323 South Wadsworth Boulevard, Suite 103, Denver, Colorado 80227, for a Site Specific Development Plan and Special Review Permit#1039 for an injection well for disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) on the following described real estate, to-wit: Part of the SW 1/4 SW 1/4 of Section 10, Township 1 North, Range 67 West of the 6th P.M., Weld County, Colorado WHEREAS, said applicant was represented by Ken Lind, Attorney, and WHEREAS, Section 24.4.2 of the Weld County Zoning Ordinance provides standards for review of said Special Review Permit, and WHEREAS,the Board of County Commissioners heard all of the testimony and statements of those present, studied the request of the applicant and the recommendations of the Weld County Planning Commission and all of the exhibits and evidence presented in this matter and, having been fully informed, finds that this request shall be approved for the following reasons: 1. The submitted materials are in compliance with the application requirements of Section 24.7 of the Weld County Zoning Ordinance. 2. It is the opinion of the Board of County Commissioners that the applicant has shown compliance with Section 24.4.2 of the Weld County Zoning Ordinance as follows: 941078 pLocr Sf3 C'�' PL . Iv/ere-ICS] L/ND)Hz, SPECIAL REVIEW PERMIT#1039 - WRIGHT'S DISPOSAL, INC. PAGE 2 a. The proposal is consistent with the Weld County Comprehensive Plan's Environmental Quality and Natural Resource Goals and Policies, Urban Growth Boundary Area Goals and Policies, and Agricultural Goals and Policies. The Weld County Comprehensive Plan's Urban Growth Boundary Area Goals encourage the maintenance of Urban Growth Boundary areas that provides an official definition between future urban and agricultural land- uses. The proposed use is not considered to be an urban type of development. The Agricultural Goals and Policies of the Weld County Comprehensive Plan encourage the location of businesses and industries in areas that minimize the removal of prime agricultural land from production. No land will be removed from production, and the facility is existing. The location of the Special Review site and the attached conditions and development standards will ensure consistency with the goals and policies of the Weld County Comprehensive Plan. b. The proposal is consistent with the intent of the Agricultural Zone District and is provided for as a Use by Special Review. This proposal will not remove prime agricultural land from production. c. The use will be compatible with the existing surrounding land uses and with the future development of the surrounding area as permitted by the existing zoning. The surrounding land uses include farm production, oil and gas production, and rural residences. d. No overlay districts affect the site. e. Special Review Development Standards will provide adequate protection of the health, safety, and welfare of the neighborhood and County. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that the application of Wright's Disposal, Inc. for a Site Specific Development Plan and Special Review Permit#1039 for an injection well for disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) on the hereinabove described parcel of land be, and hereby is, granted subject to the following conditions: 1. The attached Development Standards for the Special Review Permit shall be adopted and placed on the Special Review plat prior to recording the plat. The plat shall be delivered to the Department of Planning Services and be ready for recording in the Weld County Clerk and Recorder's Office within 30 days of approval by the Board of County Commissioners. 941078 SPECIAL REVIEW PERMIT#1039 -WRIGHT'S DISPOSAL, INC. PAGE 3 2. Within 30 days of approval by the Board of County Commissioners and prior to the injection of Class I waste: a. Evidence shall be submitted to the Department of Planning Services that any required fees from the Colorado Geological Survey and Environmental Protection Agency have been paid in full; b. A road improvements and maintenance agreement for the haul route along Weld County Road 19 north to State Highway 52 shall be submitted to Weld County Engineering Department for review and approval by the Board of County Commissioners; c. A copy of a dust abatement program for the haul route from Weld County Road 19 to the Special Review Permit site approved by the Weld County Health Department shall be submitted to the Department of Planning Services; d. The name of the facility at which any waste from this facility is to be dispensed of, including filters, shall be provided to Weld County Environmental Protection Services. 3. The property shall be maintained in compliance at all times with the Certificate of Designation approved for this facility. 4. The applicant shall notify the City of Fort Lupton, in writing, of any changes to the approved Permit. 5. Prior to recording the plat, the following note shall be attached: a. This Permit shall be valid as long as the facility is maintained in compliance with the Environmental Protection Agency. 6. The facility's water supply shall be provided by the Central Weld County Water District as indicated in the application materials. The septic system shall be approved by the Weld County Health Department. 941078 SITE SPECIFIC DEVELOPMENT PLAN SPECIAL REVIEW PERMIT DEVELOPMENT STANDARDS WRIGHT'S DISPOSAL, INC. USR#1039 1. The Site Specific Development Plan and Special Review Permit is for an injection well for disposal of nonhazardous Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) as submitted in the application materials on file and subject to the Development Standards stated herein. 2. Approval of this plan may create a vested property right pursuant to Article 68 of Title 24 C.R.S., as amended. 3. The facility shall receive only pre-approved (approval from Environmental Protection Agency, E.P.A.) Class I nonhazardous industrial waste and Class II waste as defined by the E.P.A. 4. The facility shall monitor groundwater at the site in accordance with the Hepworth-Pawlak Geotechnical, Inc. report on monitoring well installation, dated July 18, 1994, and the Colorado Department of Public Health and Environment's letter of July 19, 1994. 5. Prior to injecting a new Class I waste stream, the facility shall provide the E.P.A. Review and Approval Notice (conducted in accordance with 40 cfr, Part 261) to the Weld County Environmental Protection Services and Department of Planning Services. 6. The facility shall maintain compliance with its United States Environmental Protection Agency, Underground Injection Control Program Final Permit No. CO 1516-2115. 7. The facility shall provide Environmental Protection Services Division of the Weld County Health Department copies of all audits conducted at the facility. Specifically, the audits required twice annually by the E.P.A. shall be submitted. 8. The facility shall maintain all financial assurance in accordance with Section 1.8 of the Regulations pertaining to Solid Waste Disposal Sites and Facilities (6 CCR 1007-2), and the financial assurance shall be sufficient to remove all surface structures and any impacted soil, etc., in accordance with the closure plan submitted in the Facility Design and Operation Plan. 9. No less than five working days prior to pressure testing at the facility, the Weld County Environmental Protection Services Division shall be informed of the specific dates in order to observe the process. 941078 SPECIAL REVIEW PERMIT#1039 - WRIGHT'S DISPOSAL, INC. PAGE 4 The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 2nd day of November, A.D., 1994. U ��G A BOARD OF COUNTY COMMISSIONERS ATTEST: (,yl2(�J %ir( WELD COUNTY, COLORADO /97 Weld County Clerk to the Board A/ (. � Webster man BY: / A Deputy Clerk to the Board �— Dale K. all, Pro-Tem APPROVED AS TO FORM: �.e C� ,teorge EBaxter EXCUSED / ounty Attorney Constance L. Harbert / /Barbara J. Kirkmey' 941078 DEVELOPMENT STANDARDS - WRIGHT'S DISPOSAL, INC. PAGE 2 10. Any emergency response or release of one (1) barrel or more of waste inside or outside the bermed areas or containment areas shall be immediately reported to the Weld County Health Department Environmental Protection Services and recorded in the facility's operating record. 11. An individual sewage disposal system shall be installed according to the Weld County Individual Sewage Disposal Regulations. The septic system is required to be designed by a Colorado Registered Professional Engineer according to the Weld County Individual Sewage Disposal Regulations. 12. A three-foot by four-foot sign shall be posted at the entrance gate listing the facility name, hours of operation, and twenty-four hour emergency telephone numbers. 13. The maximum permissible noise level shall not exceed the industrial limit of 80 db(A), as measured according to Section 25-12-102, C.R.S. 14. Fugitive dust shall be controlled on the site. 15. The injection pressure at the facility shall not exceed 3,700 (p.s.i.g.) and the facility shall not inject more than 11,520 barrels of combined Class I and II waste per day. 16. All chemicals stored on the site shall be stored in locked buildings, on an impervious surface, provided manufacturer recommendations for safe storage and handling are in accord. In any event, manufacturer recommendations will take precedence. 17. Any required air emission permit shall be obtained from the Air Pollution Control Division, Colorado Department of Health. 18. The truck unloading pad around the disposal area shall be constructed of an impervious material and graded to insure that all spilled waste is contained within said truck unloading pad. 19. The facility shall comply with the laws, standards, rules and regulations of the Air Quality Control Commission, the Water Quality Control Commission, the Hazardous Materials and Solid Waste Division, the Colorado Oil and Gas Commission, the E.P.A., and any other applicable agency. 20. All records required in accordance with E.P.A., U.I.C. Permit No. CO 1516-2115 shall be made available upon request to the Weld County Planning and Weld County Health Departments. 941078 DEVELOPMENT STANDARDS -WRIGHT'S DISPOSAL, INC. PAGE 3 21. No disposal of hazardous wastes of any type shall be permitted at any time. 22. Every load of liquid waste shall be scrutinized by the facility manager or other qualified and trained employee to assure that an approved material is being received for disposal. 23. The facility shall have and keep records to document every load received at the facility. Records shall include owner, operator, driver of the trucks delivering loads, source of the load including owner/operator, name of company, location of source, amount, date loaded, and type of liquid waste shall also be kept in the records. 24. The manager of the facility or other trained and qualified employee shall be knowledgeable with the approved Special Review Permit Conditions of Approval and Development Standards, be knowledgeable in operating an injection well, and be on site at all times that the facility is open for business to receive wastes. 25. The property shall be maintained in compliance with SARA Title III. 26. A spillage retention berm around the tank battery shall be greater than the volume of the largest tank inside the berm. 27. The haul route shall be Weld County Road 19, north to State Highway 52. No hauling shall be allowed south of the entrance road on Weld County Road 19. 28. All fees required by 25-106-101, et seq., C.R.S., 1973, as amended, shall be collected by the operator and remitted to the State Health Department Hazardous Substance Response Fund. 29. This Special Review Permit facility shall be operated in accordance with Weld County Ordinance 164-A, regarding a surcharge in the amount of ten percent(10%)which is added to all fees received by an operator of solid waste disposal sites in Weld County. 30. All construction on the property shall be in accordance with the requirements of the Weld County Building Code Ordinance. 31. The property owner or operator shall be responsible for complying with the Design Standards of Section 24.5 of the Weld County Zoning Ordinance. 32. The property owner shall be responsible for complying with the Operation Standards of Section 24.6 of the Weld County Zoning Ordinance. 941078 DEVELOPMENT STANDARDS -WRIGHT'S DISPOSAL, INC. PAGE 4 33. Personnel from the Weld County Health Department, Fort Lupton Fire Protection District, and Weld County Department of Planning Services shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Development Standards stated herein and all applicable Weld County regulations. 34. The Special Review area shall be limited to the plans shown herein and governed by the foregoing Standards and all applicable Weld County Regulations. Major changes from the plans or Development Standards as shown or stated shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans or Development Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. 35. The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the Permit by the Board of County Commissioners. 941078 HEARING CERTIFICATION DOCKET NO. 94-69 RE: SITE SPECIFIC DEVELOPMENT PLAN, SPECIAL REVIEW PERMIT, AND CERTIFICATE OF DESIGNATION FOR AN INJECTION WELL FOR DISPOSAL OF CLASS I AND CLASS II LIQUID WASTE AS DEFINED IN THE CODE OF FEDERAL REGULATIONS (40 CFR 144.6) -WRIGHT'S DISPOSAL, INC. A public hearing was conducted on November 2, 1994, at 10:00 a.m., with the following present: Commissioner W. H. Webster, Chairman Commissioner Dale K. Hall, Pro-Tem Commissioner George E. Baxter Commissioner Constance L. Harbert - EXCUSED Commissioner Barbara J. Kirkmeyer Also present: Acting Clerk to the Board, Shelly Miller Assistant County Attorney, Lee Morrison Planning Department representative, Keith Schuett The following business was transacted: I hereby certify that pursuant to a notice dated September 21, 1994, and duly published September 29, 1994, in the Windsor Beacon, a public hearing was conducted to consider the request of Wright's Disposal, Inc. for a Site Specific Development Plan, Special Review Permit, and Certificate of Designation for an injection well for disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6). Lee Morrison, Assistant County Attorney, made this a matter of record. Keith Schuett, Planning Department representative, entered the favorable recommendations of the Planning Commission into the record as written. Mr. Schuett noted two separate resolutions are necessary and two motions must be made, one for the Site Specific Development Plan and Special Review Permit and one for the Certificate of Designation. Ken Lind, Attorney, represented the applicant and stated all recommendations from Planning, including the Conditions of Approval and Development Standards, are acceptable. He also stated, for the record, the applicant would like to adopt Planning staffs comments concerning compliance as detailed in Paragraph 2 of the Planning Commission's resolution. Mr. Lind stated the property is zoned Agricultural, the facility is existing, and there will be no change other than widening the road by four feet. He briefed the Board on the background of the facility and explained, since Class I liquids, which are nonhazardous, are being added, the facility must be reviewed by the EPA, the State, and the County. Mr. Lind stated a need exists in Weld County for this type of facility, and the trip fee should supply $50,000 to $100,000 revenue per year to Weld County. Martin Wohnlich, Wright's Disposal, Inc., explained the conceptual site plan, the haul route, and the transportation and processing of the fluids at the facility. Responding to questions from the Board, he stated the impurities are caught by filters, which are disposed of at a landfill. Mr. Wohnlich also explained a map detailing the cross-section of the injection well, which is 10,000 feet deep and made of the highest grade steel according to EPA standards. He explained the safety features of the 941078 941079 et: P RE: HEARING CERTIFICATION - WRIGHT'S DISPOSAL, INC. PAGE 2 facility, indicating four barriers exist between the aquifers and the disposal water and an analysis pressure gauge, which detects leaks, is checked daily; therefore, the mechanical integrity is always up to EPA standards. Mr. Wohnlich also noted the EPA has tested various components of the well, and this is the best way to dispose of industrial waste water. In response to further questions from the Board, Mr. Wohnlich explained the water goes into the Lyons Formation, which is 50 percent water-saturated and 50 percent open space. He noted the EPA will allow the saturation to increase to 60 percent, which is limited by the injection pressure. He confirmed the EPA regulates and monitors, by a monthly report, the volumes and types of fluids accepted by the facility. Mr. Wohnlich stated the existing formation easily takes fluid and the pressure does not exceed 3200 pounds. He confirmed there is no impact on faults in the area and stated extensive seismic research has been done, showing the nearest fault is two miles away, and the facility is limited to one-quarter mile around the well. Responding to further inquiries, Mr. Wohnlich stated Wrights has operated the facility since 1989 and there has been one fire and pinholes have developed in the tubing; however, the pinholes were immediately detected and the tubing was replaced. At the request of Commissioner Kirkmeyer, Mr. Wohnlich explained the emergency response procedure for the fire and stated all changes recommended by the Fort Lupton Fire Department were completed; however, the Health Department was not called. Chairman Webster noted, for the record, only four Board members were present and explained to the applicant that, in case of a tie vote, the fifth member would cast the deciding vote after reviewing the record. Mr. Wohnlich said he had no problem with the procedure. He then responded to further questions by stating the hours of operation are primarily from 6:00 a.m. to 7:00 p.m.; however, an operator stays on the site while the facility is operating and until all pumps are empty. Mr. Lind noted the Permit provides for 24-hour-per-day operation and the facility is always available for disposal, but it is not necessarily in operation 24 hours per day. He referred to the complete copy of the EPA Permit Application and Review and noted the Responsiveness Summary outlines the geological and seismic research on Pages 14 through 17. Mr. Lind reiterated the EPA has restricted the facility to a one-quarter mile radius, making it impossible for fluids to move off site, and the facility has been extensively reviewed and approved by the EPA and the State. No public testimony was offered concerning this matter. Jeff Stoll, Health Department, confirmed the facility has been reviewed and all concerns have been addressed. Responding to a question from Commissioner Kirkmeyer concerning Development Standard #15, Trevor Jiricek, Health Department, stated the facility has already been approved to accept 11,000 barrels per day; however, the applicant confirmed the facility could not exceed 5,000. Mr. Wohnlich explained 11,000 barrels was used as a theoretical number; however, the facility could not physically handle more than 3,000 to 5,000 barrels per day. He confirmed for Commissioner Baxter that the Permit would have to be amended for the facility to exceed 5,000 barrels per day. Responding to Chairman Webster, Mr. Wohnlich stated an agreement with Suckla Farms to purchase 40 acres is proposed. Mr. Lind reiterated any change to the facility must be specifically approved by the EPA who would then request review by the Board. At the request of Commissioner Kirkmeyer, Mr. Schuett clarified the Planning Commission's changes in Development Standards#18, #22, and #24. Mr. Morrison noted the State regulations concerning the financial assurance, which is for the closure of the site, are not effective until October 1995. Commissioner Kirkmeyer then requested a Development Standard be added requiring the facility to call the Health Department immediately in case of an emergency. Mr. Morrison suggested the Weld County Regional Communications Center's protocol also be reviewed. Mr. Stoll 941078 941079 RE: HEARING CERTIFICATION - WRIGHT'S DISPOSAL, INC. PAGE 3 reported that he and John Pickle, Health Department Director, provided the dispatch service with a list of facilities for which they would like to be notified in case of an emergency. Mr. Schuett confirmed that Development Standard #33 should state the Fort Lupton Fire Protection District rather than Brighton. Mr. Lind confirmed a draft road improvements agreement will be reviewed by staff and brought to the Board for approval within 30 days. Mr. Schuett and Mr. Lind confirmed the changes to Development Standards#10 and #33, concerning immediate notification of any emergency to the Health Department and changing the fire protection district from Brighton to Fort Lupton, respectively. Discussion followed concerning fencing and a gate, and Mr. Lind and Mr. Schuett clarified neither the Engineering Department nor the Sucklas want a gate. Mr. Lind further clarified the EPA has jurisdiction over the site and prohibits fencing. Mr. Wohnlich also clarified the EPA feels a fence is not necessary and could prevent rapid evacuation. He also noted the facility is physically locked when not in operation. Commissioner Hall moved to approve the request of Wright's Disposal, Inc. for a Site Specific Development Plan and Special Review Permit for an injection well for disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6), based on the recommendations of the Planning staff and the Planning Commission, with the Conditions of Approval and Development Standards as entered into the record, including the changes to Development Standards #10 and #33. Commissioner Baxter seconded the motion, which carried unanimously. Commissioner Hall moved to approve the request of Wright's Disposal, Inc., for a Certificate of Designation for an injection well for disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6), based on the recommendations of the Planning staff and the Planning Commission, with the Condition of Approval. The motion was seconded by Commissioner Baxter, and it carried unanimously. This Certification was approved on the 7th day of November, 1994. APPROVED: ATTEST: �� BOARD OF COUNTY COMMISSIONERS 4,/d /v/ WELD COUNTY, COLORADO Weld County Clerk to the oard2 J / By: iy W. H. Webster, Chair an Deputy Clerk to the Boar Dale K. Hall, Pro-Tem TAPE #94-42 George Q" Baxter DOCKET #94-69 EXCUSED Constance L. Harbert PL0688 /cAIi /rbara J. Kirkmeyer jj 941078 941079 ATTENDANCE RECORD HEARINGS ARE AS FOLLOWS ON THIS 2nd DAY OF November 3994: DOCKET 0 94-69 -- USR 01039 and Certificate of Designation, Wright's Disposal, Inc. DOCKET 0 DOCKET 0 DOCKET 0 PLEASE write or print your name legibly, your address and the DOCKET 0 (as listed above) or the name of the applicant of the hearing you are attending. NAME ADDRESS HEARING ATTENDING �719� 7',t" ii.164 4)L i'-1-/ Vii /6i/1-1i )A-s'2oi 4. f7j) ,Z,2X 2 v - ,c G ei ery duo 2 6 / i)i\Q h t'S e l €-14~ (ali,i T iS?DS T-I L 941078 .'.t b',JUllti 'JtriRUL Slit,bl' Case tas #1O- — L 104c044a) no. Exhibit Submitted By Exhibit Description q 9 • eon. Cc r ) G � 14A2:1-11t9�.�o D. .Qaxu� U� 6l I E. NM k -tn go aryl J}�?citA.c.L dd., A-' 7/Lv/ 'i ). F. (,go I ft O --3- . ,X�ttG tJ LL1- 7/19794 Cam? ) 1! 3411,_3 loo fo P.el „A he • Rol i► G. if Nut r 4 ern' J -u tin I1t� 4 ntlit Cerra nts0 Q° � a'` II H. — COVT-Tta ( )tir 44 QQ� D( / / / I. 1- 1U1 J. K. L. H. N. 0. P. Q. R. S. T. U. V. W. X. Y. Z. 941078 NOTICE The Board of County Commissioners of Weld County, Colorado, on November 2, 1994, conditionally approved a Site Specific Development Plan and Special Review Permit for the property and purpose described below. Conditional approval of this plan creates a vested property right pursuant to Article 68 of Title 24, C.R.S., as amended, for a period of three years. APPLICANT: Wright's Disposal, Inc. 2323 South Wadsworth Boulevard, Suite 103 Denver, Colorado 80227 LEGAL DESCRIPTION: Part of the SW 1/4 SW 1/4 of Section 10, Township 1 North, Range 67 West of the 6th P.M., Weld County, Colorado TYPE AND INTENSITY OF APPROVED USE: An injection well for disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) SIZE OF PARCEL: 39 acres, more or less Failure to abide by the terms and conditions of approval will result in a forfeiture of the vested property right. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO BY: DONALD D. WARDEN CLERK TO THE BOARD BY: SHELLY K. MILLER DEPUTY CLERK TO THE BOARD PUBLISHED: November 10, 1994, in the Windsor Beacon 941079 AFFIDAVIT OF PUBLICATION STATE OF COLORADO SS COUNTY OF WELD I, ROGER A. LIPKER. of said County of Weld, being duly NM= sworn,say that I am publisher of The Bard of Canty oawma "NanNovfler21994 of Weld , WINDSOR BEACON conditionally approved a Site Specific Devebpmad Plan and Special Review pu� Permit ti a weekly newspaper having a general circulation in said °hMoaplan mateanal approval a County and State, published in the town of WINDSOR, in this pea mates•veeYd praper- lyngapawemaaaa.e9d said County and State; and that the notice, of which the T6 21,CAB..as anandea,fa apeduddeeeeywa. annexed is a true copy, has been published in said weekly =Cant v tW ' eaaeaai for / successive weeks, that the notice was Boulevard, sate to Denve published in the regular and entire issue of evely number of Colorado 80227 the paper during the period and time of publication, and in Deerdp.of on:SecPan d meD. the newspaper proper and not in a supplement, and that Township ang 1ownnp i North, Range 07 the first publication of said notice was in said paper bearing West of ty,cothe ad6th . P.M" Weld the date of the..--) .� M t dry w d. _day of fvr-em-A 1 A.D., 19 91 and the ss kt last publication bearing the date of the vedam a clan t and n the n Cods of Faded Re nad in as w h day of A.D., 19_ and that 144,6 the said WINDSOR BEACON has been published Size d Pero*99 acres,mere or continuously and uninterruptedly for the period of 5 lane consecutive weeks, in sa,.; orgy and State, prior to the Fain t abide w the twins and date of first publication of said notice, and the same is a =dials al approval WI result in akMlawd the woadpug newspaper within the meaning of an Act to regulate printing "hddtt of legal notices and advertisements, approved May 18, Bawd of Commissioners M C01le 1931,and all prior acts so far as in force. Colorado i OS"Ihs awe / t/ — Ilillf gews+ e�1 maw � ISHER Noon wsr.r 4444 +wI f bscribed and sworn to before me this /u Be. day of f"1 G4'& -'-/ 19 q/c/ X711-4/ K' 7�,e NOTARY PUBLIC My commission expires -e=t 2/ j�/ ?l 941078 NOTICE Pursuant to the zoning laws of the State of Colorado and the Weld County Zoning Ordinance, a public hearing will be held in the Chambers of the Board of County Commissioners of Weld County, Colorado, Weld County Centennial Center, 915 10th Street, First Floor, Greeley, Colorado, at the time he Developmentspecified. All pelso s in any manner interested in the Site Specific Permit, and Certificate of Designation are requested to attend and may be heard. Should the applicant or any interested party desire the presence of a court record hpchtwr to make a record the hearing,f the proceedings,he lerk to addition Board shall beadvised which will n be kept u during in a of court ch action at least five reporter shall be borne by s the prior requesting hearing. party. The cost of engaging BE IT ALSO KNOWN that the text and maps so certified by the Weld County Planning Commission may be examined in the office of the Clerk to the Board of County Commissioners, located in the Weld County Centennial Center, 915 10th Street, Third Floor, Greeley, Colorado. APPLICANT DOCKET NO: 94-69 Wright's Disposal, Inc. 2323 South Wadsworth Boulevard, Suite 103 Denver, Colorado 80227 DATE: November 2, 1994 TIME: 10:00 a.m. ew Permit,REQUEST: Certificatpecof1Designation PlA Site an, well for and for disposal Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) LEGAL DESCRIPTION: Part of the SW* SW,' of Section 10, Township 1 North, Range 67 West of the 6th P.M. , Weld County, Colorado LOCATION: Approximately 2.5 miles southeast of the Town of Dacono,he Wed aroximatelyes west of south oftStatety of Fo Highway 5 Lupton, east of 2 BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO BY: DONALD D. WARDEN WELD COUNTY CLERK TO THE BOARD BY: SHELLY K. MILLER DEPUTY CLERK TO THE BOARD DATED: September 21, 1994 PUBLISHED: September 29, 1994, in the Windsor Beacon EX 941078 h cbi � NOTICE Pursuant to the zoning laws of Me State of Colorado and the Weld County Zoning Ordinance, a public hearing will be held in the Chambers of the Board of County Commissioners of Weld County, Colorado, Weld County Centennial Center,915 10th Street, First Floor. Greeley,Colorado,at the time AFFIDAVIT OF PUBLICATION • specified. All persons in any manner interested in the Site Specific Development Plan,: STATE OF COLORADO special Review Permit, and a SS Certificate of Designation are requested to attend and may COUNTY OF WELD be heard. • Should the applicant or any I, ROGER A. LIPKER, of said County of Weld, being duly interested parry desire the sworn,say that I publisher of • presence of a court reporter to am make a record of the proceed- ings, in addition to the taped WINDSOR BEACON record which will be kept dur- ing the hearing,the Clerk to the Board shall be advised In a weekly newspaper having a general circulation in said writing of such action at last five days poor to the hearing.l County and State, published in the town of WINDSOR, in The cost of engaging a OMNI said County and State; and that the notice, of which the reporter shall be borne by the requesting pony. annexed is a true copy, has been published in said weekly BE IT ALSO KNOWN Nat Pie / successive weeks, that the notice was text and maps so certified by published in the regular and entire issue of every number at the Weld County Planning the paper during the period and time of publication, and in Commission may be examined in the office of the Clerk to the , the newspaper proper and not in a.supplement, and that Board of County the first publication of said notice was in said paper bearing Commissioners,located in the Weld County Centennial the date of the Center,91s tom Sheet,Third 7Z day of ;6 4'-di- tom- ��- A.D., 19`7`� and the Floor,Greeley,Colorado. last publication bearing the date of the DOCKET NO:94-69 _day of A.D., 19 and that APPLICANT Wright's the said WINDSOR.. 3EACON has been published Disposal, Inc. 2323 South continuously and I•ainterruptedly for the period of 5 Wadsworth Boulevard, Suite consecutive weeks, in said County and State, prior to the •103 DenveryColpraEo gogz7 date of first publication of said notice, and the same is a DATE:November 2,1994 newspaper within the meaning of an Act to regulate printing TIME:10:00 a.m. of legal notices and advertisements, approved May 18, REQUEST: A Site Specific 1931, arid Jall prior acts so far as in force. • Review Permit,and Certificate io of Designation for anCl injection nd well for disposal of ife and Class II liquid waste as ISHER in the Code of Federal Regulations(40 cfr 144.6) • 4 a LEGAL DESCRIPTION: Part Subscribed and sworn to before me this 29 day of of the SWIM SW1/4 of Section 2/ {<eh_/-G=— 19 l7 10.Township 1 North,Range • 67 West of the 6th P.M.,Weld y Count',Colorado 0 �ryrq LOCATION: Approximately NOTARY BLIC 2.5 miles southeast of the Town of Dacono,approximate-, --7 y 2.5 miles west of the City of I My Commission expires "9L-, / /- , ! Fort Lupton, east of Weld County Road 19,and south of Setae Highway 52 BOARD OF COUNTY COM- MISSIONERS • WELD COUNTY.COLORADO BY:DONALD D.WARDEN WELD COUNTY CLERK TO THE BOARD BY:SHELLY K.MILLER DEPUTY CLERK TO THE BOARD DATED:SepWn er 21,1994 •Published M the Windee. Beecon on September 29, 1MM. 941078 CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the foregoing Notice of Hearing, Docket #94-69, was placed in the United States mail, first class mail, postage prepaid, '-4 DATED this day of .6)-(71131X1-_, , 1994. WRIGHT'S DISPOSAL, INC. 2323 SOUTH WADSWORTH BOULEVARD SUITE 103 DENVER, CO 80227 KEN LIND 1011 11TH AVENUE GREELEY, CO 80631 SUCKLA FARMS, INC. 4468 WELD COUNTY ROAD 19 FORT LUPTON, CO 80621 COLUMBINE JERSEY FARMS, INC. 45 SOUTH LOOKOUT MOUNTAIN CIRCLE GOLDEN, CO 80401 AMOCO PRODUCTION COMPANY P.O. BOX 800 DENVER, CO 80201 tL Deputy Clerk the Board 941079 BEFORE THE WELD COUNTY, COLORADO, PLANNING COMMISSION RESOLUTION OF RECOMMENDATION TO THE BOARD OF COUNTY COMMISSIONERS Moved by Bud Clemons that the following resolution be introduced for passage by the Weld County Planning Commission. Be it resolved by the Weld County Planning Commission that the application for: NAME: Wright's Disposal, Inc. f ADDRESS: 2323 South Wadsworth Blvd. , Suite 103, Denver, CO 80227 , ; r ^? REQUEST: A Certificate of designation for an injection well for the disposal of- Class I and Class II liquid waste as defined in the Code of Fede,Y,al - Regulations (40 cfr 144.6) . v LEGAL DESCRIPTION: Part of the SW4 SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 2.5 miles southeast of the Town of Dacono, approximately 2.5 miles south west of the City of Ft. Lupton, east of Weld County Road 19, and south of State Highway 52. be recommended favorably to the Board of County Commissioners for the following reasons: 1. The conditions of approval and stated standards in Special Review Permit 1039 will minimize the impacts on the surrounding property and the area to the greatest extent possible. The conditions of approval and stated standards will also provide adequate protection of the health, safety, and welfare of the inhabitants of the area and the county. 2. The location of the proposed solid waste disposal site will be convenient and accessible to the potential users. 3. The applicant has demonstrated in the submitted application materials that there is a need for the proposed solid waste disposal site. 4. The applicant has demonstrated in the submitted application materials the ability to comply with the health standards and operating procedures of the Solid Waste Disposal Site and Facilities Act, Title 30-20, Part 1, Colorado revised Statutes. 5. The Colorado Department of Health and the Weld Health Department have reviewed this request and find, subject to conditions, that the proposal will comply with the Standards of the Solid Waste Disposal Sites and Facilities Act, Title 30-20-101 et seq. , Colorado Revised Statutes. 941079 Ekhtbd+ G RESOLUTION, USR-1039 - Certificate of Designation Wright's Disposal, Inc. Page 2 This recommendation is based, in part, upon a review of the application materials submitted by the applicant, other relevant information regarding the request and the responses of the referral entities which have reviewed this request. The Planning Commission's recommendation for approval is conditional upon the following: The property shall be maintained in compliance with USR-1039, All submitted application materials on file with the Department of Planning Services, and all requirements of the Weld County Health Department, the Colorado Department of Health, and the Environmental Protection Department. Motion seconded by Ron Sommer. VOTE: For Passage Against Passage Curt Moore Shirley Camenisch Bud Clemons Marie Koolstra Ron Sommer Richard Kimmel The Chairperson declared the resolution passed and ordered that a certified copy be forwarded with the file of this case to the Board of County Commissioners for further proceedings. CERTIFICATION OF COPY I, Sharyn Ruff, Recording Secretary for the Weld County Planning Commission, do hereby certify that the above and foregoing resolution, is a true copy of the resolution of the Planning Commission of Weld County, Colorado, adopted on September 8, 1994. Dated the 8th of September, 994 aryn F. '1 ff � Secretary 941078 BEFORE THE WELD COUNTY, COLORADO, PLANNING COMMISSION RESOLUTION OF RECOMMENDATION TO THE BOARD OF COUNTY COMMISSIONERS Moved by Bud Clemons, that the following resolution with amendments to Development Standards #18, 22, and 24, be introduced for passage by the Weld County Planning Commission. Be it resolved by the Weld County Planning Commission that the application for: CASE NUMBER: USR-1039 NAME: Wright's Disposal, Inc. ADDRESS: 2323 South Wadsworth Blvd. , Suite 103 (j Denver, CO 80227 w REQUEST: A Site Specific Development Plan and a Special Review permit for an injection well for disposal of nonhazardous Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) . LEGAL DESCRIPTION: Part of the SW4 SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 2.5 miles southeast of the Town of Dacono, approximately 2.5 miles southwest of the City of Ft. Lupton, east of Weld County road 19, and south of State Highway 52. be recommended favorably to the Board of County Commissioners for the following reasons: 1. The submitted materials are in compliance with the application requirements of Section 24.7 of the Weld County Zoning Ordinance. 2. It is the opinion of the Planning Commission that the applicant has shown compliance with Section 24.3 of the Weld County Zoning Ordinance as follows: The proposal is consistent with the Weld County Comprehensive Plan's Environmental Quality and Natural Resource Goals and Policies, Urban Growth Boundary Area Goals and Policies, and the Agricultural Goals and Policies. The Weld County Comprehensive Plan's Urban Growth Boundary Area Goals encourage the maintenance of Urban Growth Boundary areas that provides an official definition between future urban and agricultural land-uses. The proposed use is not considered to be an urban type of development. The Agricultural Goals and Policies of the Weld county Comprehensive Plan encourage the location of businesses and industries in areas that minimize the removal of prime agricultural land from production. No land will be removed from production, the facility is existing. The location of the Special Review site and the attached conditions and development standards will ensure consistency with the goals and policies of the Weld County Comprehensive Plan. 941079 RESOLUTION, USR-1039 Wright's Disposal, Inc. Page 2 - The proposal is consistent with the intent of the Agricultural zone district and is provided for as a Use by Special Review. This proposal will not remove prime agricultural land from production. - The use will be compatible with the existing surrounding land uses and with the future development of the surrounding area as permitted by the existing zoning. The surrounding land uses include farm production, oil and gas production, and rural residences. - No overlay districts affect the site. Special Review Development Standards will provide adequate protection of the health, safety, and welfare of the neighborhood and County. This recommendation is based, in part, upon a review of the application materials submitted by the applicant, other relevant information regarding the request, and responses from referral entities. The Planning Commission's recommenation for approval is conditional upon the following: 1. The attached Development Standards for the Special Review permit shall be adopted and placed on the Special Review plat prior to recording the plat. The plat shall be delivered to the Department of Planning Services and be ready for recording in the Weld County Clerk and Recorder's office within 30 days of approval by the Board of County Commissioners 2. Within 30 days of approval by the Board of County Commissioners and prior to the injection of Class I waste: a. evidence shall be submitted to the Department of Planning Services that any required fees from the Colorado Geological Survey and Environmental Protection Agency have been paid in full; b. a road improvements and maintenance agreement for the haul route along Weld County Road 19 north to State Highway 52 shall be submitted to Weld County Engineering Department for review and approval by the Board of County Commissioners; c. a copy of a dust abatement program for the haul route from Weld County Road 19 to the Special Review permit site approved by the Weld County Health Department shall be submitted to the Department of Planning Services; and 941075 RESOLUTION, USR-1039 Wright's Disposal, Inc. Page 3 d. The name of the facility at which any waste from the facility is to be dispensed of, including filters, shall be provided to Weld County Environmental Protection Services. 3. The property shall be maintained in compliance at all times with the Certificate of Designation approved for this facility. 4. The applicant shall notify the City of Ft. Lupton, in writing, of any changes to the approved permit. 5. Prior to recording the plat, the following note shall be attached: This permit shall be valid as long as the facility is maintained in compliance with the Environmental Protection Agency. 6. The facility's water supply shall be provided by the Central Weld County Water District as indicated in the application materials. The septic system shall be approved by the Weld County Health Department. Motion seconded by Curt Moore. VOTE: For Passage Against Passage Curt Moore Shirley Camenisch Bud Clemons Marie Koolstra Ron Sommer Richard Kimmel The Chairperson declared the resolution passed and ordered that a certified copy be forwarded with the file of this case to the Board of County Commissioners for further proceedings. CERTIFICATION OF COPY I, Sharyn Ruff, Recording Secretary for the Weld County Planning Commission, do hereby certify that the above and foregoing resolution, is a true copy of the resolution of the Planning Commission of Weld County, Colorado, adopted on September 8, 1994. Dated the 8th d y of Sep tuber, 1994. haryn F. Ruff Secretary 941979 SITE SPECIFIC DEVELOPMENT PLAN SPECIAL REVIEW PERMIT DEVELOPMENT STANDARDS Wright's Disposal, Inc. USR-1039 1. The Site Specific Development Plan and Special Review permit is for an injection well for disposal of nonhazardous Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) as submitted in the application materials on file in the Department of Planning Services and subject to the Development Standards stated hereon. 2. Approval of this plan may create a vested property right pursuant to Article 68 of Title 24 C.R.S. , as amended. 3. The facility shall receive only pre-approved (approval from Environmental Protection Agency (E.P.A. ) Class I non-hazardous industrial waste and Class II waste as defined by the E.P.A. 4. The facility shall monitor groundwater at the site in accordance with the Hepworth-Pawlak Geotechnical, Inc. , report on monitoring well installation dated July 18, 1994, and the Colorado Department of Public Health and Environment's letter of July 19, 1994. 5. Prior to injecting a new Class I waste stream, the facility shall provide the E.P.A. Review and Approval Notice (conducted in accordance with 40 cfr, Part 261) to the Weld County Environmental Protection Services and Department of Planning Services. 6. The facility shall maintain compliance with its United States Environmental Protection Agency, Underground injection Control program Final Permit No. : CO 1516-2115. 7. The facility shall provide Environmental Protection Services Division of the Weld County health Department copies of all audits conducted at the facility. Specifically, the audits required twice annually by the E.P.A. shall be submitted. 8. The facility shall maintain all financial assurance in accordance with Section 1.8 of the Regulations pertaining to Solid Waste Disposal Sites and Facilities (6 CCR 1007-2), the financial assurance shall be sufficient to remove all surface structures and any impacted soil, etc. , in accordance with the closure plan submitted in the Facility Design and Operation Plan. 9. No less than five working days prior to pressure testing at the facility, the Weld County Environmental Protection Services Division shall be informed of the specific dates in order to observe the process. 941079 DEVELOPMENT STANDARDS, USR-1039 Wright's Disposal, Inc. Page 2 10. Any release of one (1) barrel or more of waste inside or outside of the bermed areas or containment areas shall be reported within 24 hours of detection of the spill to the Weld County Health Department Environmental Protection Services and recorded in the facility's operating record. 11. An individual sewage disposal system shall be installed according to the Weld County Individual Sewage Disposal Regulations. The septic system is required to be designed by a Colorado Registered Professional Engineer according to the Weld County Individual Sewage Disposal Regulations. 12. A 3-foot by 4-foot sign shall be posted at the entrance gate listing the facility name, hours of operation, and twenty-four hour emergency telephone numbers. 13. The maximum permissible noise level shall not exceed the industrial limit of 80 db(a) , as measured according to Section 25-12-102, C.R.S. 14. Fugitive dust shall be controlled on the site. 15. The injection pressure at the facility shall not exceed 3, 700 (p.s.i.g) and the facility shall not inject more than 11,520 barrels of combined Class I and II waste per day. 16. All chemicals stored on-site shall be stored in locked buildings, on an impervious surface, provided manufacturer recommendations for safe storage and handling are in accord. In any event, manufacturer recommendations will take precedence. 17. Any required air emission permit shall be obtained from the Air Pollution Control Division, Colorado Department of Health. 18. The truck unloading pad around the disposal area shall be constructed of an impervious material and graded to insure that all spilled waste is contained within said truck unloading pad. 19. The facility shall comply with the laws, standards, rules and regulations of the Air Quality Control Commission, the Water Quality Control Commission, the Hazardous Materials and Solid Waste Division, the Colorado Oil and Gas Commission, the E.P.A. and any other applicable agency. 20. All records required in accordance with E.P.A. , U.I.C. Permit No. CO 1516- 2115 shall be made available upon request to the Weld County Planning and Weld County Health Departments. 21. No disposal of hazardous wastes of any type shall be permitted at any time. 94107E DEVELOPMENT STANDARDS, USR-1039 Wright's Disposal, Inc. Page 3 22. Every load of liquid waste shall be scrutinized by the facility manager or other qualified and trained employee to assure that an approved material is being received for disposal. 23. The facility shall have and keep records to document every load received at the facility. Records shall include owner, operator, and driver of the trucks delivering loads, source of the load including owner/operator, name of company, location of source, amount, date loaded, and type of liquid waste shall also be kept in the records. 24. The manager of the facility or other trained and qualified employee shall be knowledgeable with the approved Special Review permit conditions and development standards, be knowledgeable in operating an injection well, and be on site at all times that the facility is open for business to receive wastes. 25. The property shall be maintained in compliance with SARA Title III. 26. A spillage retention berm around the tank battery shall be greater than the volume of the largest tank inside the berm. 27. The haul route shall be Weld County Road 19 north to State Highway 52. No hauling shall be allowed south of the entrance road on Weld County Road 19. 28. All fees required by 25-106-101, et seq. , C.R.S. , 1973, as amended, shall be collected by the operator and remitted to the State Health Department Hazardous Substance Response Fund. 29. This Special Review Permit facility shall be operated in accordance with Weld County Ordinance 164 A. , regarding a surcharge in the amount of ten percent (10%) which is added to all fees received by an operator of solid waste disposal sites in Weld County. 30. All construction on the property shall be in accordance with the requirements of the Weld County Building Code Ordinance. 31. The property owner or operator shall be responsible for complying with the Design Standards of Section 24.5 of the Weld County Zoning Ordinance. 32. The property owner shall be responsible for complying with the Operation Standards of Section 24.6 of the Weld County Zoning Ordinance. 941079 DEVELOPMENT STANDARDS, USR-1039 Wright's Disposal, Inc. Page 4 33. Personnel from the Weld County Health Department, Brighton Fire Protection District, and Weld County Department of Planning Services shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Development Standards stated hereon and all applicable Weld County Regulations. 34. The Special Review area shall be limited to the plans shown hereon and governed by the foregoing Standards and all applicable Weld County Regulations. Major changes from the plans or Development Standards as shown or stated shall require the approval of an amendment of the permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans or Development Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. 35. The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the permit by the Board of County Commissioners 941079 INVENTORY OF ITEMS SUBMITTED FOR CONSIDERATION APPLICANT: Wrights Disposal, Inc. CASE NUMBER: USR-1039 and Certificate of Disposal Submitted or prepared Prior to Hearing At Hearing 1. Application 223 pages X 2. 1 Application plat of one page X 3. Department of Planning Services Referral summary sheet X 4. Department of Planning Services letter to the applicant X 5. Department of Planning Services Recommendation X 6. Department of Planning Services Surrounding Property Owners/Mineral Owners X 7. 3 Department of Planning Services Maps Prepared by Planning Technician X 8. Department of Planning Services Notice of Hearing X 9. Department of Planning Services Case Summary Sheet X 10. Department of Planning Services Field Check X 11. Memorandum from Ed Herring WCSO X 12. Referral response from Larry Richardson, Ft. Lupton Fire Protection X 13. Memorandum from Don Carrol, Weld County Public Works X 14. Referral Response form K.N. Front Range Gathering Co. X 15. Referral Response from Central Weld County Water District X 16. Referral Response from Platte Valley Soil Conservation District X 17. Letter dated January 5, 1994 from Ralph Camble X 18. Letter from Tri-Area Planning Commission X 19. Letter from Ken Lind dated January 11, 1994 X 20. Letter form Don Stephens dated January 15, 1994 X 21. Referral response form Colorado Oil and Gas Conservation Com. X 22. Letter from Farmers Reservoir and Irrigation Company X 23. Memorandum from Don Carrol, Weld County Public Works X 24. Memorandum form Drew Scheltinga, Weld County Public Works X 25. Memorandum Dated July 28,1994 from Trevor Jiricek, Health Dept. X 26. Memorandum Dated August 25,1994 From Drew Scheltinga X 27. Agreement for the sale of real estate X 28. Letter dated December 15, 1994 From Ken Lind X 29. Letter dated December 15, 1994 from Karina Thomas X 30. Letter dated December 20, 1994 from Ken Lind X 31. Letter dated January 5, 1994 from Ken Lind X 32. Letter Dated January 25, 1994 from Lee Morrison X ki f A 9410'79 exit 33. Letter dated January 27, 1994 from Stephen Laudeman X 34. Letter dated February 8, 1994 from Ken Lind X 35. Letter dated March 2, 1994 from Lee Morrison X 36. Letter dated April 5, 1994 from Ken Lind X 37. Letter dated April 14, 1994 from Keith Schuett X 38. Letter dated may 19, 1994 From Stephen Laudeman X 39. Letter from Karina Thomas dated June 23, 1994 X 40 Fax letter from Martin Wohnlich dated July 21, 1994 X 41. Letter from Ken Lind dated July 22, 1994 X 42. Fax letter from Martin Wohnlich X 43. Letter dated July 21, 1994 from Stephen Laudeman and Glenn Mallory X 44. Letter dated June 9, 1994 from Stephen Laudeman X 45. Letter dated April 20, 1994 from Trevor Jiricek X 46. Ordinance 164-A Recorded November 6, 1992 X 47. Proposed changes to Development Standards X I hereby certify that the 47 items identified herein were submitted to the Department of Planning Services at or prior to the scheduled Planning Commission Hearing. I further certify that these items were forwarded to the Clerk to the Board's office on mber 0, 1994. K ' . Schuett urrent Planner II STATE OF COLORADO ) ) COUNTY OF WELD ) SUBSCRIBED AND SWORN TO BEFORE ME THIS 20 DAY OF SE TEMBE 4. `1 `^Yew nnr,,,, : + .. •.. ....;, tom: 42r'tt 0 TA / .n: ••. NOTARY UBLI `My!&on-1n!icsign Expires November 21, 1995. 941.079 SUMMARY OF .THE WELD COUNTY PLANNING COMMISSION MEETING September 8, 1994 Page 4 William Schmoll, applicant, explained he and his wife are very involved in the care of horses for their private use. His wife is an avid barrel racer and they built this outbuilding as a "home" for their horses. Mr. Schmoll stated that he checked the covenants for the subdivision before building and they stated nothing in excess of 2000 square feet for outbuildings and he did not realize that County rules of 1500 square feet maximum (which he was not aware of) would supersede the covenants for the subdivision. The Chairman asked if there was anyone in the audience who wished to speak for or against this application. No one wished to speak. Ron Sommer moved Case Number, USR-1056, William F. and Laura A. Schmoll, be forwarded to the Board of County Commissioners with the Planning Commission's recommendation for approval. Bud Clemons seconded the motion. The Chairman asked the secretary to poll the members of the Planning Commission for their decision. Curt Moore - yes; Shirley Camenisch - yes; Bud Clemons - yes; Marie Koolstra - yes; Ron Sommer - yes; Richard Kimmel - yes. Motion carried unanimously. CASE NUMBER: USR-1039 APPLICANT: Wright's Disposal, Inc. REQUEST: A Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and II nonhazardous liquid waste as defined in the code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. LEGAL DESCRIPTION: Part of the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: One mile south of State Highway 52; approximately 1/2 mile east of Weld County Road 19. Ken Lind, Attorney, explained the injection well has been in existence since 1976 for the disposal of brine water. This application for the disposal of Class I and II nonhazardous liquid waste has been approved through the Colorado Oil and Gas Conservation Commission, the Colorado State Health Department, and the Weld County Health Department. He asked if the Planning Commission had any questions regarding this application. Discussion followed. The applicant had concerns about the wording on Development Standards #18, 22, and 24. Keith Schuett had no problems with the changes. Martin Vorlick gave and overview of the facility. The Chairman asked if there was anyone in the audience who wished to speak for or against this application. No one wished to speak. �� f 941078 SUMMARY OF THE WELD COUNTY PLANNING COMMISSION MEETING September 8, 1994 Page 5 Bud Clemons moved Case Number USR-1039, Wright's Disposal, Inc. , be forwarded to the Board of County Commissioners, as amended, with the Planning Commission's recommendation for approval. Curt Moore seconded the motion. The Chairman asked the secretary to poll the members of the Planning Commission for their decision. Curt Moore - yes; Shirley Camenisch - yes; Bud Clemons - yes; Marie Koolstra - yes; Ron Sommer - yes; Richard Kimmel - yes. Motion. carried unanimously. Bud Clemons moved the Certificate of Designation for Case Number USR-1039, Wright's Disposal, Inc. , be forwarded to the Board of County Commissioners with the Planning Commission's recommendation for approval. Ron Sommer seconded the motion. The Chairman asked the secretary to poll the members of the Planning Commission for their decision. Curt Moore - yes; Shirley Camenisch - yes; Bud Clemons - yes; Marie Koolstra - yes; Ron Sommer - yes; Richard Kimmel - yes. Motion carried unanimously. Meeting ad urne 4:55 p.m. s ctful submitted Sharyn F. uff Secretary MEMORAnDUM To Planning nepartment Date October 12, 1994 COLORADO From Lee n Morrison, Assistant County Attorney Wright' s Disposal - Road Improvements and suniectMintenance Agreement The agreement should be modified to require payment within 30 days of a 90 day notice that Weld County is going to pave WCR 19 where traffic is over 120 vehicles . Any interest accumulated on funds deposited by Wright ' s pending payment on the project could be returned to Wright' s . The agreement should address the situation where traffic is less than 120 vehicles per day at the time of paving but later increases . The payment should still be required for maintenance overlay or chip and seal . The $21, 500 should be subject to annual adjustments for inflation in accordance with the Producer Price Index for Total Finished Goods published by the Department of Labor and Statistics of the United States Department of Labor the first adjustment to be January 1, 1996 . The agreement needs a new paragraph to provide that, in addition to any other remedies, failure to comply may be grounds for revocation of the permit . ee S. Morri o ssistant Weld County Attorney LDM/gb:drew pc: Drew Scheltinga r; t+'1 ckj C_ _' C C] cr. C S J to ikOCT ^ ' 1994 ;j F.v.^ +)fJi LIL.n:5.� Cy hLbL-k- Q 941078 STATE OF COLORADO Roy Romer,Governor Co Patricia A.Nolan,MD,MPH,Executive Director a5'oF Dedicated to protecting and improving the health and environment of the people of Colorado N� 4 ' a * 4300 Cherry Creek Dr.S. Laboratory Building «�.,• ,.�!,r Denver,Colorado 80222-1530 4210 E.11th Avenue "re76 Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 Colorado Department July 21, 1994 of Public Health and Environment Weld County Board of County Commissioners - County Commissioners Office _, 915 10th Street Greeley, Colorado 80632 ri m c RE: Certificate of Designation Application Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado ,O C) Dear Commissioners: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Wright's Disposal Inc.'s Certificate of Designation Application to operate a liquid waste disposal facility in Weld County. The Division hereby determines that, based on information submitted by the applicant and subsequent correspondence, and contingent the requirements stated in the Division's July 19, 1994 letter to Mr. Martin Wohnlich being adequately addressed, all requirements of the Solid Wastes Disposal Sites and Facilities Act (C.R.S. 30-20-1 et seq.) have been met. A copy of the July 19, 1994 letter is enclosed. This determination serves as recommendation to the Weld County Board of County Commissioners that a Certificate of Designation for solid waste disposal as documented in the referenced Wright's Disposal submittals may be granted for this facility. I hope this letter clearly states the Division's position on the status of this facility. If you have any questions regarding this matter, please contact me at (303) 692-3462. Sincere , Ste en deman lenn F. Mallory Geol gical Engineer Section Chief �. Solid Waste Section Solid Waste Section Hazardous Materials Hazardous Materials and Waste Management Division and Waste Management Division enslosure cc: Martin Wohnlich, Wright's Disposal, Inc. w/o enclosure Kenneth Lind, Lind, Lawrence, and Ottenhoff w/o enclosure Keith Schuett, Weld County Planning Department w/ enclosure Trevor Jiricek, Weld County Department of Health w/o enclosure John Carson, US Environmental Protection Agency w/o enclosure Patricia Beaver, Colorado Oil and Gas Conservation Commission w/o enclosure File: SW/WLD/WRI/2 ; 4 /AL ; frec 66) 941078 &W ad- F- STATE OF COLORADO Roy Romer,Governor op'cota Patricia A.Nolan,MD,MPH,Executive Director €4;- N =-;„:- Dedicated to protecting and improving the health and environment of the people of Colorado * �. `9 4300 Cherry Creek Dr.S. Laboratory Building Denver,Colorado 80222-1530 4210 E.11th Avenue * 76 s .te Phone(303)692-2000 Denver,Colorado 80220-3716 Colorado Department (303)691-4700 of Public Health and Environment July 19, 1994 Mr. Martin Wohnlich Wright's Disposal, Inc. 2323 South Wadsworth Blvd., Suite 103 Denver, Colorado 80227 RE: Certificate of Designation Application Technical Review Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Mr. Wohnlich: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Hepworth-Pawlak Geotechnical, Inc.'s letter of July 18, 1993 regarding installation of ground water monitoring wells at the Wright's Disposal facility. These ground water monitoring wells were installed in response to concerns expressed in the Division's June 9, 1994 letter. Based on a review of the information provided, the Division finds that the three wells as installed (designated OW-1, OW-2, and OW-3) will serve to satisfy the Division's request for installation of a ground water monitoring system. As we have discussed, the last remaining concerns of the Division have to do with the parameter list for monitoring and the monitoring frequency. The Division requires that the minimum parameter list consist of the constituents listed in Appendix IA of the Solid Waste Regulations (6 CCR 1007-2) and benzene, ethyl benzene, toluene, and xylene, (BTEX) and Total Petroleum Hydrocarbons (TPH). All sampling and analyses must follow standard accepted protocols and utilize EPA approved methods. A copy of Appendix I of the Regulations is enclosed for your reference. The Division requires that individual samples be obtained from each well and analyzed on a semi-annual basis (twice per year). In addition to obtaining samples for analysis, it will be necessary to determine the elevation of water in each well at each sampling event and use this information to determine the direction of flow and the magnitude of the hydraulic gradient. All analytical results and other monitoring information must be submitted to the Division and Weld County Health Department after each sampling event. As all concerns of the Division regarding the Certificate of Designation Application for this facility have now been met, a letter will be sent to the Weld County Planning Department recommmending approval of Wright's Disposal's Application for a Certificate of Designation. I hope this letter clearly states the Division's position on the status of this facility. If you have 941078 Mr. Martin Wohnlich July 19, 1994 Page 2 any questions regarding this matter, please contact me at (303) 692-3462. Sincerely, Stephe Lau an Geolog al Engineer Solid Waste Section Hazardous Materials and Waste Management Division enclosure cc: Kenneth Lind, Lind, Lawrence, and Ottenhoff Trevor Jiricek, Weld County Department of Health w/copy of July 18, 1994 letter John Carson, US Environmental Protection Agency w/copy of July 18, 1994 letter Patricia Beaver, Colorado Oil and Gas Conservation Commission File: SW/WLD/WRI/2 941078 DATE: September 2, 1994 CASE NUMBER: USR-1039 NAME: Wright's Disposal, Inc. ADDRESS: 2323 South Wadsworth Blvd. , Suite 103 Denver, CO 80227 REQUEST: A Site Specific Development Plan and a Special Review permit for an injection well for disposal of nonhazardous Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) . LEGAL DESCRIPTION: Part of the SW4 SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 2.5 miles southeast of the Town of Dacono, approximately 2.5 miles southwest of the City of Ft. Lupton, east of Weld County road 19, and south of State Highway 52. THE DEPARTMENT OF PLANNING SERVICES' STAFF RECOMMENDS THAT THIS REQUEST BE APPROVED FOR THE FOLLOWING REASONS: 1. The submitted materials are in compliance with the application requirements of Section 24.7 of the Weld County Zoning Ordinance. 2. It is the opinion of the Department of Planning Services' staff that the applicant has shown compliance with Section 24.3 of the Weld County Zoning Ordinance as follows: The proposal is consistent with the Weld County Comprehensive Plan's Environmental Quality and Natural Resource Goals and Policies, Urban Growth Boundary Area Goals and Policies, and the Agricultural Goals and Policies. The Weld County Comprehensive Plan's Urban Growth Boundary Area Goals encourage the maintenance of Urban Growth Boundary areas that provides an official definition between future urban and agricultural land-uses. The proposed use is not considered to be an urban type of development. The Agricultural Goals and Policies of the Weld county Comprehensive Plan encourage the location of businesses and industries in areas that minimize the removal of prime agricultural land from production. No land will be removed from production, the facility is existing. The location of the Special Review site and the attached conditions and development standards will ensure consistency with the goals and policies of the Weld County Comprehensive Plan. The proposal is consistent with the intent of the Agricultural zone district and is provided for as a Use by Special Review. This proposal will not remove prime agricultural land from production. EXMfRIT it le I 94107_ RECOMMENDATION, USR-1039 Wright's Disposal, Inc. Page 2 - The use will be compatible with the existing surrounding land uses and with the future development of the surrounding area as permitted by the existing zoning. The surrounding land uses include farm production, oil and gas production, and rural residences. - No overlay districts affect the site. - Special Review Development Standards will provide adequate protection of the health, safety, and welfare of the neighborhood and County. This recommendation is based, in part, upon a review of the application materials submitted by the applicant, other relevant information regarding the request, and responses from referral entities. The Department of Planning Services' staff recommenation for approval is conditional upon the following: 1. The attached Development Standards for the Special Review permit shall be adopted and placed on the Special Review plat prior to recording the plat. The plat shall be delivered to the Department of Planning Services and be ready for recording in the Weld County Clerk and Recorder's office within 30 days of approval by the Board of County Commissioners 2. Within 30 days of approval by the Board of County Commissioners and prior to the injection of Class I waste: a. evidence shall be submitted to the Department of Planning Services that any required fees from the Colorado Geological Survey and Environmental Protection Agency have been paid in full; b. a road improvements and maintenance agreement for the haul route along Weld County Road 19 north to State Highway 52 shall be submitted to Weld County Engineering Department for review and approval by the Board of County Commissioners; c. a copy of a dust abatement program for the haul route from Weld County Road 19 to the Special Review permit site approved by the Weld County Health Department shall be submitted to the Department of Planning Services; and 941078 RECOMMENDATION, USR-1039 Wright's Disposal, Inc. Page 3 d. The name of the facility at which any waste from the facility is to be dispensed of, including filters, shall be provided to Weld County Environmental Protection Services. 3. The property shall be maintained in compliance at all times with the Certificate of Designation approved for this facility. 4. The applicant shall notify the City of Ft. Lupton, in writing, of any changes to the approved permit. 5. Prior to recording the plat, the following note shall be attached: This permit shall be valid as long as the facility is maintained in compliance with the Environmental Protection Agency. 6. The facility's water supply shall be provided by the Central Weld County Water District as indicated in the application materials. The septic system shall be approved by the Weld County Health Department. 941078 SITE SPECIFIC DEVELOPMENT PLAN SPECIAL REVIEW PERMIT DEVELOPMENT STANDARDS Wright's Disposal, Inc. USR-1039 1. The Site Specific Development Plan and Special Review permit is for an injection well for disposal of nonhazardous Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) as submitted in the application materials on file in the Department of Planning Services and subject to the Development Standards stated hereon. 2. Approval of this plan may create a vested property right pursuant to Article 68 of Title 24 C.R.S. , as amended. �Tl 3. The facility shall receive only pre-approved (approval from Env* ,•nmental Protection Agency (E.P.A. ) Class I non-hazardous industria waste/ and Class II waste as defined by the E.P.A. 4. The facility shall monitor groundwater at the site in accordan - the Hepworth-Pawlak Geotechnical, Inc. , report on monitoring well installation dated July 18, 1994, and the Colorado Department of Public Health and Environment's letter of July 19, 1994. 5. Prior to injecting a new Class I waste stream, the facility shall provide the E.P.A. Review and Approval Notice (conducted in accordance with 40 cfr, Part 261) to the Weld County Environmental Protection Services and Department of Planning Services. 6. The facility shall maintain compliance with its United States Environmental Protection Agency, Underground injection Control program Final Permit No. : CO 1516-2115. 7. The facility shall provide Environmental Protection Services Division of the Weld County health Department copies of all audits conducted at the facility. Specifically, the audits required twice annually by the E.P.A. shall be submitted. 8. The facility shall maintain all financial assurance in accordance with Section 1.8 of the Regulations pertaining to Solid Waste Disposal Sites and Facilities (6 CCR 1007-2) , the financial assurance shall be sufficient to remove all surface structures and any impacted soil, etc. , in accordance with the closure plan submitted in the Facility Design and Operation Plan. 9. No less than five working days prior to pressure testing at the facility, the Weld County Environmental Protection Services Division shall be informed of the specific dates in order to observe the process. 94107E DEVELOPMENT STANDARDS, USR-1039 Wright's Disposal, Inc. Page 2 10. Any release of one (1) barrel or more of waste inside or outside of the bermed areas or containment areas shall be reported within 24 hours of detection of the spill to the Weld County Health Department Environmental Protection Services and recorded in the facility's operating record. 11. An individual sewage disposal system shall be installed according to the Weld County Individual Sewage Disposal Regulations. The septic system is required to be designed by a Colorado Registered Professional Engineer according to the Weld County Individual Sewage Disposal Regulations. 12. A 3-foot by 4-foot sign shall be posted at the entrance gate listing the facility name, hours of operation, and twenty-four hour emergency telephone numbers. 13. The maximum permissible noise level shall not exceed the industrial limit of 80 db(a) , as measured according to Section 25-12-102, C.R.S. 14. Fugitive dust shall be controlled on the site. 15. The injection pressure at the facility shall not exceed 3, 700 (p.s.i.g) and the facility shall not inject more than 11,520 barrels of combined Class I and II waste per day. 16. All chemicals stored on-site shall be stored in locked buildings, on an impervious surface, provided manufacturer recommendations for safe storage and handling are in accord. In any event, manufacturer recommendations will take precedence. 17. Any required air emission permit shall be obtained from the Air Pollution ntrol Division, Colorado Department of Health. 18. %)The surf.c s a t e disposal area shall be constructed of an io im erv %� graded to insure that all spilled waste is P -e'+` containe wi hin the unloading pad. 19. The facility shall comply with the laws, standards, rules and regulations of the Air Quality Control Commission, the Water Quality Control Commission, the Hazardous Materials and Solid Waste Division, the Colorado Oil and Gas Commission, the E.P.A. and any other applicable agency. 20. All records required in accordance with E.P.A. , U.I.C. Permit No. CO 1516- 2115 shall be made available upon request to the Weld County Planning and Weld County Health Departments. 21. No disposal of hazardous wastes of any type shall be permitted at any time. 941078 DEVELOPMENT STANDARDS, USR-1039 Wright's Disposal, Inc. Page 3 22. Every load of liquid waste shall be scrutinized by the facility manager to assure that an approved material is being received for disposal. 23. The facility shall have and keep records to document every load received at the facility. Records shall include owner, operator, and driver of the trucks delivering loads, source of the load including owner/operator, name of company, location of source, amount, date loaded, and type of liquid waste shall also be kept in the records. 24. The manager of the facility shall be knowledgeable with the approved Special Review permit conditions and development standards, be knowledgeable in operating an injection well, and be on site at all times that the facility is open for business to receive wastes. 25. The property shall be maintained in compliance with SARA Title III. 26. A spillage retention berm around the tank battery shall be greater than the volume of the largest tank inside the berm. 27. The haul route shall be Weld County Road 19 north to State Highway 52. No hauling shall be allowed south of the entrance road on Weld County Road 19. 28. All fees required by 25-106-101, et seq. , C.R.S. , 1973, as amended, shall be collected by the operator and remitted to the State Health Department Hazardous Substance Response Fund. 29. This Special Review Permit facility shall be operated in accordance with Weld County Ordinance 164 A. , regarding a surcharge in the amount of ten percent (10%) which is added to all fees received by an operator of solid waste disposal sites in Weld County. 30. All construction on the property shall be in accordance with the requirements of the Weld County Building Code Ordinance. 31. The property owner or operator shall be responsible for complying with the Design Standards of Section 24.5 of the Weld County Zoning Ordinance. 32. The property owner shall be responsible for complying with the Operation Standards of Section 24.6 of the Weld County Zoning Ordinance. 33. Personnel from the Weld County Health Department, Brighton Fire Protection District, and Weld County Department of Planning Services shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Development Standards stated hereon and all applicable Weld County Regulations. 941079 DEVELOPMENT STANDARDS, USR-1039 Wright's Disposal, Inc. Page 4 34. The Special Review area shall be limited to the plans shown hereon and governed by the foregoing Standards and all applicable Weld County Regulations. Major changes from the plans or Development Standards as shown or stated shall require the approval of an amendment of the permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans or Development Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. 35. The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the permit by the Board of County Commissioners 941079 CERTIFICATE OF DESIGNATION DATE: September 8, 1994 NAME: Wright's Disposal, Inc. ADDRESS: 2323 South Wadsworth Blvd. , Suite 103, Denver, CO 80227 REQUEST: A Certificate of designation for an injection well for the disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) . LEGAL DESCRIPTION: Part of the SW4 SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 2.5 miles southeast of the Town of Dacono, approximately 2.5 miles south west of the City of Ft. Lupton, east of Weld County Road 19, and south of State Highway 52. THE DEPARTMENT OF PLANNING SERVICES' STAFF RECOMMENDS THAT THIS REQUEST BE APPROVED FOR THE FOLLOWING REASONS: 1. The conditions of approval and stated standards in Special Review Permit 1039 will minimize the impacts on the surrounding property and the area to the greatest extent possible. The conditions of approval and stated standards will also provide adequate protection of the health, safety, and welfare of the inhabitants of the area and the county. 2. The location of the proposed solid waste disposal site will be convenient and accessible to the potential users. 3. The applicant has demonstrated in the submitted application materials that there is a need for the proposed solid waste disposal site. 4. The applicant has demonstrated in the submitted application materials the ability to comply with the health standards and operating procedures of the Solid Waste Disposal Site and Facilities Act, Title 30-20, Part 1, Colorado revised Statutes. 5. The Colorado Department of Health and the Weld Health Department have reviewed this request and find, subject to conditions, that the proposal will comply with the Standards of the Solid Waste Disposal Sites and Facilities Act, Title 30-20-101 et seq. , Colorado Revised Statutes. This recommendation is based, in part, upon a review of the application materials submitted by the applicant, other relevant information regarding the request and the responses of the referral entities which have reviewed this request. U Nlilt .._i.- ' 41078 RECOMMENDATION, USR-1039 Wright's Disposal, Inc. Page 2 The Department of Planning Services' staff recommendation for approval is conditional upon the following: The property shall be maintained in compliance with USR-1039, All submitted application materials on file with the Department of Planning Services, and all requirements of the Weld County Health Department, the Colorado Department of Health, and the Environmental Protection Department. 941479 SURROUNDING PROPERTY OWNERS AND/OR SUBSURFACE ESTATE/INTEREST OWNERS Wright's Disposal, Inc. USR-0139 Suckle Farms, Inc. 4468 Weld County Road 19 Ft. Lupton, CO 80621 Columbine Jersey Farms, Inc. 45 S. Lookout Mountain Circle Golden, CO 80401 Amoco Production Company P.O. Box 800 Denver, CO 80201 EXMfIJT 1 _1 tr 9 • �' Y ,G y 1 (I' n Y / c � • � tl r Z�,)� � r•G•;•%227..,, . "' t. •3F' er � •if '� �`el yO" 'p •,a r i Y 44 i 4 „ 4L ?•4:1 • • rrtift LFl n . a� s 'p: A : w l ' y Y.. / a ••k ; tea , Y. Y 1 -r G' p Gi° C t �i i e G' [f 'l•4 •[ 7c -� , l ' 9e ' rr � Y•• • . A .. 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" ,# <yYM Yom, ''y„ 103 5,Y 1 x ar c ' r^ 11t, Y- _ Say -tT •3„;1'CX+a`cat: . +�" ₹a 5eh .. :`#%a S. > Y 'x3 Ik 4d t'�E. US 4' YfT# e as -4 �: .e:r�:. � ti'S5Y` `E. Y ( �I 4 x r DEPARTMENT OF PLANNING SERVICES PHONE (303)353-3845, EXT. 3540 WI ID WELD COUNTY ADMINISTRATIVE OFFICES 1400 GREELEY, N. ORAAVENUEO631 COLORADO 80631 COLORADO Date: December 21, 1993 CASE NUMBER: USR-1039 TO WHOM IT MAY CONCERN: Enclosed is an application from Wright's Disposal, Inc. , for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and Class II nonhazardous liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. The parcel of land is approximately 40 acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. The location of the parcel of land for which this application has been submitted is one mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. This application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Your prompt reply will help to facilitate the processing of the application and will ensure prompt consideration of your recommendation. Please reply by January 4, 1994, so that we may give full consideration to your recommendation. Please call Keith A. Schuett, Current Planner, if you have any questions about the application. Check the appropriate boxes below and return to our address listed above. t 1. We have reviewed this request and find that it does/does not) comply with our Comprehensive Plan for the following reasons. 2. We do not have a Comprehensive Plan, but we feel this request (is/is not) compatible with the interests of our town for the following reasons: 3. We have reviewed the request and find no conflicts with our interests. 4. A formal recommendation is under consideration and will be submitted to you prior to: 5. Please refer to the enclosed letter. Signed: Agency: Date: 9410'7`3 REFERRAL LIST NAME: Wright's Disposal, Inc. CASE NUMBER: USR-1039 REFERRALS SENT: December 17, 1993 REFERRALS TO BE RECEIVED BY: December 31, 1993 COUNTY TOWNS and CITIES X Attorney Ault X Health Department Brighton Extension Service Broomfield X Emergency Management Office X Dacono Sheriff' s Office _Eaton X Engineering _Erie _Housing Authority _Evans Airport Authority Firestone X Building Inspection XFort Lupton Frederick STATE Garden City Division of Water Resources ____Gilcrest Geological Survey Greeley X Department of Health Grover _Department of Transportation Hudson _Historical Society Johnstown Water Conservation Board Keenesburg _ X Oil and Gas Conservation Commission Kersey La Salle FIRE DISTRICTS Lochbuie Ault F-1 _Longmont _ Berthoud F-2 Mead _ Briggsdale F-24 _Milliken _Brighton F-3 New Raymer Eaton F-4 Northglenn _ X Fort Lupton F-5 Nunn Galeton F-6 Pierce Hudson F-7 Platteville Johnstown F-8 ____Severance La Salle F-9 Thornton Mountain View F-10 ____Windsor Milliken F-11 _ Nunn F-12 COUNTIES Pawnee F-22 Adams _ Platteville F-13 Boulder _ _Platte Valley F-14 Larimer _Poudre Valley F-15 _Raymer F-2 FEDERAL GOVERNMENT AGENCIES Southeast Weld F-16 US Army Corps of Engineers _ _Windsor/Severance F-17 USDA-APHIS Veterinary Service Wiggins F-18 ____Federal Aviation Administration Western Hills F-20 ____Federal Communication Commission OTHER SOIL CONSERVATION DISTRICTS X Central Colo. Water Conservancy Dist. X Brighton X Panhandle Eastern Pipe Line Co. Fort Collins X Tri-Area Planning Commission Greeley X Central Colo Water Conservancy Dist. Longmont X Central Weld Water District West Adams X tuull Ditch Ccmpeiay - I-15-9` COMMISSION/BOARD MEMBER X Juliette Kroekel 941078 P1�ner I DEPARTMENT OF PLANNING SERVICES PHONE(303)353-3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES 140WI I D C. GREELEY, N. ORAAVENUEO631 COLORADO 80631 COLORADO NOTICE OF PUBLIC HEARING The Weld County Planning Commission will hold a public hearing on Thursday, September 8, 1994, at 1:30 p.m. for the purpose of considering a Site Specific Development Plan, Special Review permit, and a Certificate of Designation for the property described below. Approval of the request may create a vested property right pursuant to Colorado Law. APPLICANT: Wright's Disposal, Inc. LEGAL DESCRIPTION: 39 acres being located in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. TYPE AND INTENSITY OF PROPOSED USE: An injection well for the disposal of Class I and II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. LOCATION: One mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. SIZE: 39 acres, more or less. The public hearing will be held in the Weld County Commissioners' Hearing Room, First Floor, Weld County Centennial Center, 915 Tenth Street, Greeley, Colorado. Comments or objections related to the above request should be submitted in writing to the Weld County Department of Planning Services, 1400 N. 17th Avenue, Greeley, Colorado 80631, before the above date or presented at the public hearing on September 8, 1994. Copies of the application are available for public inspection in the Department of Planning Services, 1400 N. 17th Avenue, Greeley, Colorado 80631. Please call Becky Dittman, at Phone II (303) 353-6100, Ext. 3540, or Fax It (303) 351- 0978, prior to the day of the hearing so that reasonable accommodations can be made if, in accordance with the Amercians with Disabilities Act, you require special accommodations in order to participate in this hearing as a result of a disability. " Judy Yamaguchi, Chairperson Weld County Planning Commission To be published in the Windsor Beacon To be published on, (1) time by August 11, 1994. Received/17: ' Date: � y + IXMISIT 941078 aaoEmtwn HEARIN The Weld County Planning Commission will hold a pub- lic hearing on Thursday, September 8,1994,at 1:30 AFFIDAVIT OF PUBUCATION p.m.for the purpose of con- sidering a Site specific Developers Plan,spacial STATE OF COLORADO Review panes, and a ss Certificate rd Da armaan for the (,.wady dasomad COUNTY OF WELD below. Aaprwal et the request may arrr a walled I, ROGER A. LIP property Wilt Pala 19 KER, of said County of Weld, being duly Colorado Law. sworn,say that I am publisher of I APPLICANT wright's WINDSOR BEACON Disposal,Inc. LEGAL DESCRIPTION: 39 a weekly newspaper having a general circulation in said acres being located In the S2 County and State, published in the town of WINDSOR, in apOoxi E2 of awe mihe said County and State; and that the notice, of which the SW4 of Section 10, TIN, annexed is a true copy, has been published in said weekly R67W of the 6th P.M.,Weld County,Colorado. for / successive weeks, that the notice was TYPE AND INTENSITY OF published in the regular and entire issue of every number of . PROPOSED USE:An injec- the paper during the period and time of publication, and in lion well for the disposal of the newspaper proper and not in a supplement, and that Class I and II liquid e waste as the first publication of said notice was in said paper bearing a I in the Code s Federal Regulations (40 cfr the�,�date of the /j zone district.in the A(A9rloueureq //.14 day of /2a A.D., 199¢ and the 144.)in LOCATION:One mile scum last publication bearinjthe date of the of State Highway 52 end _day of , A.D., 19_ and that approximately yl2omile9east the said WINDSOR BEACON has been published continuously and uninterruptedly for the period of 5 SIZE:39 acres,more or less. consecutive weeks, in said County and State, prior to the The public hearing will be crate of first publication of said rotre, and the same is a held in the Weld County newspaper within the meaning of an Act to regulate printing Commissioners' Hearing Room, First Floor, Weld of legal notices and advertisements, approved May 18, County Centennial Center, 1931,and all prior acts so far as in force. 915 Tenth Street, Greeley, Cole Comments or objections related to the above b d In writing n told be ‘jt---A._ (/f/_a r In stsh ro the - • Weld County Department of ISHER Planning Services, 1400 N. 17th Avenue, Greeley, �/ Colorado 80631, before the Sub/^�/�.rt�bed and sworn to before me this/� day of above date b or arinntee at on ! 19 9 the public hearing I September 8,1994. �) y/v� /jam Copies of the application are . ,Sy e /2tc'i available for public inspes- lion in the Department of NOTARY PUBLIC Planting Services, 1400 N. ((ny�� ^,�,17th A080631. Greeley, My commission expires �" / 2,/99 6 7 venue, f' Please call Becky Dittman,at Phone a (303) 353-6100, Eq. 3540, or Fax 4 (303) 3510878,prior to the day of t the hearing so that reason- able accommodations can be made if, in accordance with the Amercians with Disabilities Act, you require e. special accommodations in order to participate In this • hearing sea resod W-erss- ability." Judy Yamaguchi, Chairperson Weld County ,` Planning Commission �I ,s�I��U�{.�� r'n‘I Pptllalwd In Ise qa tm 1m ^ �I Beason en Amiga 11, 1944. a Il�; AUG lye ' y 941079 CERTIFICATE OF MAILING i hereby certify that I have placed a true and correct copy of the surrounding property owners and owners and lessees of minerals in accordance with the notification requirements of Weld County in Case Number USR-1039 for Wright's Disposal, Inc. , in the United States Mail, postage prepaid First Class Mail by letter as addressed on the at c ist. this Sth day of August, 1994. 941.079 ct DEPARTMENT OF PLANNING SERVICES PHONE(303)353-3845, EXT.3540 WELD COUNTY ADMINISTRATIVE OFFICES 140C. GREELEY, N. ORAAVENUEO631 COLORADO 80631 COLORADO DATE: August 2, 1994 TO: SURROUNDING PROPERTY/MINERAL OWNERS CASE NUMBER: USA-1039 There will be a Public Hearing before the Weld County Planning Commission on Thursday, September 8, 1994, at 1:30 p.m. , in the County Commissioners' Hearing Room, First Floor, Weld County Centennial Center, 915 10th Street, Greeley, Colorado concerning the request of: NAME: Wright's Disposal, Inc. FOR: A Site Specific Development Plan, Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. LEGAL DESCRIPTION: 39 acre being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: One mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. Your property is within five-hundred (500) feet of the property on which this request has been made or you may have an interest in the minerals located under the property under consideration. For additional information write or telephone Keith A. Schuett, Current Planner. Comments or objections related to the above request should be submitted in writing to the Weld County Department of Planning Services, 1400 N. 17th Avenue, Greeley, Colorado 80631, on or before the date of public hearing. 9410'79 LAND- USE APPLICATION SUMMARY SHEET NAME: Wright's Disposal, Inc. DATE: September 8, 1994 ADDRESS: 2323 South Wadsworth Blvd. , Suite 103 REQUEST: A Certificate of Designation for an injection well for the disposal of Class I and Class II liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) . LEGAL DESCRIPTION: Part of the SW4 SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 2.5 miles southeast of the Town of Dacono, approximately 2.5 miles south west of the City of Ft. Lupton, east of Weld County Road 19, and south of State Highway 52. POSSIBLE ISSUES SUMMARIZED FROM APPLICATION MATERIALS: This request for a Certificate of Designation is in conjunction with a Special Review permit. The Special Review permit must be reviewed first and if approved then action may be taken on the Certificate of Designation. This proposal requires two separate actions by the Planning Commission. The Planning Commission must approve a recommendation to the Board of County Commissioners consistent with the requirements listed in Section 24.3 of the Weld County Zoning Ordinance for the Special Review permit. The Planning Commission must also approve a recommendation to the Board of County Commissioners consistent with Section 45.4 of the Weld County Zoning Ordinance for the Certificate of Designation. Section 45.4 of the Weld County Zoning Ordinance provides that the Planning Commission shall be guided in its review of a Certificate of Designation by regulations contained in the State Statutes, and the Code of Colorado Regulations. A copy of Section 30-20-104 C.R.S. , identifying the factors to be considered for the review of a Certificate of Designation is enclosed. Historically, the Planning Commission has listened to all testimony required for both actions and then developed two separate recommendations. No objections have been received by the Department of Planning Services' staff from surrounding property owners. if 9410'79 btOtt6 Z00'293d TV:80 76. 0Z Nnr �p�p C y ry b b y 'A w P YY• Q1Y1 S . FNiSi LYg u p v ro w' t• oSo3asa Pflj 4 ' ;flll 'JIlI .t4 III UPUDIWI g•�i g - I iPi it > ci1° ;t1t�a, i ' a 19'iill41 11u : d gl ed C ✓�g 2. ff' 123 ; 4. � r, .00 . IA m p 'o ,,- a g - e °9.110u15 •�. s gg btt a IWi p a }y�I*UIIft C �C It ia44 4)2 P SS Xg , i Q 1.!; IU s. P . 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LEGAL DESCRIPTION: Part of the SW4 SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 2.5 miles southeast of the Town of Dacono, approximately 2.5 miles south west of the City of Ft. Lupton, east of Weld County Road 19, and south of State Highway 52. POSSIBLE ISSUES SUMMARIZED FROM APPLICATION MATERIALS: This request for a Certificate of Designation is in conjunction with a Special Review permit. The Special Review permit must be reviewed first and if approved then action may be taken on the Certificate of Designation. This proposal requires two separate actions by the Planning Commission. The Planning Commission must approve a recommendation to the Board of County Commissioners consistent with the requirements listed in Section 24.3 of the Weld County Zoning Ordinance for the Special Review permit. The Planning Commission must also approve a recommendation to the Board of County Commissioners consistent with Section 45. 4 of the Weld County Zoning Ordinance for the Certificate of Designation. Section 45.4 of the Weld County Zoning Ordinance provides that the Planning Commission shall be guided in its review of a Certificate of Designation by regulations contained in the State Statutes, and the Code of Colorado Regulations. A copy of Section 30-20-104 C.R.S. , identifying the factors to be considered for the review of a Certificate of Designation is enclosed. Historically, the Planning Commission has listened to all testimony required for both actions and then developed two separate recommendations. No objections have been received by the Department of Planning Services ' staff from surrounding property owners. 941079 E00'Said Tb:80 VS, OE Nlf .� L V V WI •O tp] q ® �.'w O p E to A CO V N N a� F N rl o 2 A >c%1 :4 . 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J•.1, sa g `A «•- T. aN �m f AtIfl4a!;i11 ' A<a `eR flu' E �. i q ..a 90 'd 98:8 NOW 66-0a-Nff __ 94107,3 iii (t. ' WELD COUNTY OFFICE OF EMERGENCY MANAGEMENT will 910 10TH AVENUE .nasemws GREELEY, CO 80631 C. Esmerpressiamswester COLORADO TO: Keith A. Schuett FROM: Ed Herring $7 DATE: December 22, 1993 REF: USR-1039 In reviewing the application from Wright's Disposal, Inc. I was not sure if they currently were disposing of brine water or have only been doing tests. I was unable to locate any Superfund Amendment and Reauthorization Act (SARA) Title III section 311 or 312 reports. These reports are required if 10, 000 pounds or more of any chemical is stored for any length of time. I would request that Wright Disposal, Inc. be required to file SARA Title III section 311 and 312 reports when they meet the threshold of any chemical. i ExM1e EC 2 8 1993 ' County Planning 941.0'79 H41° / DEPARTMENT OF PLANNING SERVICES n❑�7 PHONE (303) 353-3645, EXT. 3540 ' 0 'r„)( �� WELD COUNTY ADMINISTRATIVE OFFICES i C1aa 1400 N. 17TH AVENUE 4'",`✓ �'' OW n 9 �ptz GREELEY, COLORADO 80631 q: is. C.3 COLORADO wags County Planning k'• Date: December 21, 1993 CASE NUMBER: USR-1039 TO WHOM IT MAY CONCERN: Enclosed is an application from Wright' s Disposal, Inc. , for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and Class II nonhazardous liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. The parcel of land is approximately 40 acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. The location of the parcel of land for which this application has been submitted is one mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. This application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Your prompt reply will help to facilitate the processing of the application and will ensure prompt consideration of your recommendation. Please reply by January 4, 1994, so that we may give full consideration to your recommendation. Please call Keith A. Schuett, Current Planner, if you have any questions about the application. Check the appropriate boxes below and return to our address listed above. 1. We have reviewed this request and find that it does/does not) comply with our Comprehensive Plan for the following reasons. 2. We do not have a Comprehensive Plan, but we feel this request (is/is not) compatible with the interests of our town for the following reasons: 3. ✓ We have reviewed the request and find no conflicts with our interests. 4. A formal recommendation is under consideration and will be submitted to you prior to: 5. Please refer to the enclosed letter. Signed: - i /�iri v Agency: cT- Lu/AC1A.� 77a''L' %.c2 * 4,„ SI? Date: / �-� -2 - 9 3 4r_ . .fit mEmoRAnDum Keith Wi`kSchuett 7o ng Date December 30. 1993 COLORADO From Dnnnld Carrn11 Subject: Wright's Disposal Inc. USR - 1039 I have reviewed the application and have the following comments: ACCESS ROAD - The site is located in the center of the section with the access road running out to WCR 19. I have checked the ADT counts on WCR 19 and show a count of 267 vehicles. The count was taken somewhere between WCR 2 and State Highway 52. The applicant is stating under maximum number of users an estimate of 200 vehicles per week. It is estimated that the average weekly user on a year round basis would be 120 trucks delivering per week, and it is also estimated that the lowest usage would be an average of 60 trucks delivering per week. Weld County Engineering Department is recommending a designated haul route be established on WCR 19 and also a road maintenance agreement be entered into with the applicant. A new access to the public right-of-way should be constructed using a depth of 4" of aggregate base course and a culvert at the entrance, if required, with flared radius sections. The applicant is indicating that the access road is 20' wide. This could be a little tight for two-way semi-truck traffic. I would suggest trying to acquire a little more right-of-way to make this a safer situation. STORM-WATER RETENTION - The applicant is indicating there is no storm-water retention. The USR regulations require storm-water retention facilities should be provided on-site which are designed to retain a storm-water runoff for the full developed site from a 100-year storm. The applicant is indicating a pump house building, an office building, and a concrete pad for an unloading area. These areas would be displacing runoff water. I would like to see a storm drainage report and calculations to prove to me that we do not need a storm-water facility. DC/pds:mscheutt g cc: Commissioner Baxter DEC 3 0 1993 ' I File USR-1039 °MPtd CM*Planning EXHIBIT Ig • Iii it ••• • DEPARTMENT OF PLANNING SERVICES aC PHONE (303)353-3845, EXT. 3540 ' WELD COUNTY ADMINISTRATIVE OFFICES , 1400 N. 17TH AVENUE O GREELEY, COLORADO 80631 COLORADO JAN 0 6 1994 J Weld County Planning Date: December 21, 1993 ASE NUMBER: USR-1O39 TO WHOM IT MAY CONCERN: Enclosed is an application from Wright' s Disposal, Inc. , for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and Class II nonhazardous liquid waste as defined in the Code of Federal Regulations (4O cfr 144.6) in the A (Agricultural) zone district. The parcel of land is approximately 4O acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. The location of the parcel of land for which this application has been submitted is one mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. This application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Your prompt reply will help to facilitate the processing of the application and will ensure prompt consideration of your recommendation. Please reply by January 4, 1994, so that we may give full consideration to your recommendation. Please call Keith A. Schuett, Current Planner, if you have any questions about the application. Check the appropriate boxes below and return to our address listed above. 1. We have reviewed this request and find that it does/does not) comply with our Comprehensive Plan for the following reasons. 2. We do not have a Comprehensive Plan, but we feel this request (is/is not) compatible with the interests of our town for the following reasons: 3 . j� We have reviewed the request and find no conflicts with our interests. • EXHIBIT 4. A formal recommendation is under consideration and will b submitted to you prior to: 5. Plea e refer to the enclosed letter. Signed:~ ' Agency: R N ri- c,.2C IlA r r�P C�9 "� „3 0 Date: 1—l(-1/41 941079 4177411. NT OF PLANNING SERVICES If rtltr" PHONE (303)353-3845, EXT. 3540 SJY D COUNTY ADMINISTRATIVE OFFICES rx r JAN ' 0 tOQA 1400 N. 17TH AVENUE kGREELEY, COLORADO 80631 COLORADO "a hi E'nnnti Planning Date: December 21, 1993 CASE NUMBER: USR-1039 TO WHOM IT MAY CONCERN: Enclosed is an application from Wright' s Disposal, Inc. , for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and Class II nonhazardous liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. The parcel of land is approximately 40 acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. The location of the parcel of land for which this application has been submitted is one mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. This application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Your prompt reply will help to facilitate the processing of the application and will ensure prompt consideration of your recommendation. Please reply by January 4,1994, so that we may give full consideration to your recommendation. Please call Keith A. Schuett, Current Planner, if you have any questions about the application. Check the appropriate boxes below and return to our address listed above. 1. We have reviewed this request and find that it does/does not) comply with our Comprehensive Plan for the following reasons. 2. We do not have a Comprehensive Plan, but we feel this request (is/is not) compatible with the interests of our town for the following reasons: 3. r We have reviewed the request and find no conflicts with our interests. id EXHIBIT 4. A formal recommendation is under consideration and will ₹ submitted to you prior to: 5. Please refer to the enclosed letter. Signed:,,' Agency: /i � atZe y - Date: iSfr 941078 ry - DEPARTMENT OF PLANNING SERVICES PHONE (303) 353-3845, EXT. 3540 DWELD COUNTY ADMINISTRATIVE OFFICES ® J z I49� 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 • `Mold enmity PI811111 COLORADO Date: December 21, 1993 CASE NUMBER: USR-1039 TO WHOM IT MAY CONCERN: Enclosed is an application from Wright' s Disposal, Inc. , for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and Class II nonhazardous liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. The parcel of land is approximately 40 acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, TIN, R67W of the 6th P.M. , Weld County, Colorado. The location of the parcel of land for which this application has been submitted is one mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. This application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Your prompt reply will help to facilitate the processing of the application and will ensure prompt consideration of your recommendation. Please reply by January 4, 1994, so that we may give full consideration to your recommendation. Please call Keith A. Schuett, Current Planner, if you have any questions about the application. Check the appropriate boxes below and return to our address listed above. 1. We have reviewed this request and find that it does/does not) comply with our Comprehensive Plan for the following reasons . 2. We do not have a Comprehensive Plan, but we feel this request (is/is not) compatible with the interests of our town for the following reasons: 3. We have reviewed the request and find no conflicts with our interests . 4. A formal recommendation is under consideration and will be submitted to you prior to: 5. _. lease refer to the enclosed letter. Signed:j'Ce 7iti ) t'f.� 'Agency: l f�✓ ,ni r Date: j—/O f // + EXMIi1T • __ PLATTE VALLEY 60 S . 27th Ave . SOIL CONSERVATION Brighton, Co. 80601 DISTRICT 303-659-7004 January 5, 1993 arPF15-7 -. Mr. Keith A. Schuett Current Planner ! JAN 1 2 1994 Weld County Dept . of Planning Services Weld County administrative Offices lMnIA CauMyPlanning 1400 N. 17th Ave . Greeley, Co. 80631 RE: Case Number USR-1039, Injection well for Wright' s Disposal Dear Mr. Schuett : We have reviewed the submitted materials sent to us for special review. Potential for Runoff and Seep ***************************** If the French drain, that has been constructed along the north and west sides of the containment unit, fails the runoff and seepage that would occur has the potential to contaminate local ground water and adjacent agricultural soils . There is a ravine that runs directly northwest of the facility, that leads both to the Bull Ditch and Dry Creek, each within three-quarters of a mile from the facility. The facility is at an elevation of approximately 5060 feet, the Bull Ditch is at an elevation of 5030 feet and the Big Dry Creek is at an elevation of approximately 4080 feet, thus giving runoff water a direct path to ground water sources and agricultural soils at lower elevations . Furthermore, the seepage potential for the majority of this site is at a moderate to rapid rate . If the drainage system failed, allowing seepage to occur, the contaminated water would percolate downwards to the next impervious layer. Following gravitational pull to the next available water source at a lower elevation. Additional Safeguards Needed to Avoid Runoff and Seepage ******************************************************** There has already been one complaint of brine water runoff on to adjacent fields from the well ; obviously a lack of measures taken to prevent runoff . Even though the operator corrected the situation promptly, the damage was already 4 • EXHIBIT ( ? . t ! r. done . Once sodium adheres itself to soil particles, it is very difficult to remove . Therefore, we question the adequacy of the safeguards taken to avoid runoff and seepage . Is there a back-up system for the french drain? Are the sump pump systems adequate to handle a spill from an entire truck load of contaminated water? Are the operators running the facility adequately trained to respond immediately to a failure in the system? Such as a leaking tube or collar? The retainer walls surrounding the facility are 12 inches high-adequate enough to hold a spill of 431 barrels, one barrel over the size of the largest storage tank, but what if a spill from two storage tanks occurs? Please consider our comments and if you have further questions, feel free to call . Thank-you. Sinc ely Ra h Campbell Platte Valley Soil Conservation District 941.0'79 TRI-AREA PLANNING COMMISSION P.O. BOX 363 FREDERICK, COLORADO 80530 JAN 0 7 1994 L _ Weld County Department of Planning Services WPM County Planning 1400 North 17th Avenue Greeley, CO 80631 Attention: Keith Schuett Re: Wright ' s Disposal , Inc . Case Number USR-1039 Dear Mr. Schuett : At the regular meeting on 4 January 1994 of the Tri-Area Planning Commission, representing Firestone, Frederick, Dacono, and additional areas , the above captioned application was considered. Martin Wohnlich and Ken Mersfelder representing Wright ' s Disposal , answered the questions raised and were most helpful in providing operational information. Southwest Weld County has been the scene of increased well drilling activity as well as the recipient of several new Class II injection wells . Because of the impacts experienced of late , the Commission recommends approval of the application subject to the minimal following requirements . 1 . FENCING The operations area should be security fenced with a gate . Although hauling operations occur primarily during daylight hours, and the facility operates twenty-four hours daily, provisions should be made for complete security on holidays or as a result of operational changes in the life span of the facility. In addition to the posting of identification and emergency information at the road 19 entrance , provisions should be made to secure the access road by fencing and a gate . 2 . ROUTING Since the service area and acceptable materials are substantially increased , the potential traffic impacts could be significant . Access routing is addressed in the application only as WCR 19 and the plant road . Over the life of the operation, the potential traffic impact could be significant to WCR 19 . All local residents driving over the county roads, are acutely aware of the ever increasing truck traffic. The contention was advanced that the Class I operation would decrease traffic because it ' s more profitable than handling Class II fluids . While appearing plausible, if as stated, this is the only facility within 11 EX$1$1T Colorado and operates non-stop, the possible future impacts are predictable. Routing impacts were considered in the ANG application , south of Hwy. 52 on WCR 19 , and practical experience leads to the conclusion that such requirements are largely ignored and virtually unenforceable . Since the routing described is non-specific , then the economic responsibilities for increased traffic impacts are also vague and minimally bounded by I-25 , WCR 2 , HWY 85 , and HWY 66 . 3 . PARTICULATES Dust , known in polite circles as suspended particulate matter , increasingly creates a pall in this area of the county. This negative impact is the direct result of burgeoning truck traffic. Considering the points raised previously and the potential for growth, particularly over twenty to thirty years of operation, paving of WCR 19 south of HWY 52 , and north of WCR 2 on WCR 19 , to the access road ( including left turn lanes ) , as a joint effort by not only the applicant , but all of the other contributors , would at least control the existing problems . 4 . UTILITIES During our discussion, the applicant indicated the property purchased includes a well . Potable water should be provided by either Central Weld Water or the domestic well . Also , an approved septic system should replace the portable units now being used . The activity levels anticipated would clearly indicate the need for employee facilities . Submitted 6 January 1994 . rtis , Chairman cc:Wright ' s Disposal 941078 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LAW BUILDING 1011 ELEVENTH AVENUE P.O. BOX 326 GREELEY, COLORADO 80632 GEORGE H. OTTENHOFF TELEPHONE KENNETH F. LIND (303) 353-2323 KIM R. LAWRENCE January 11, 1994 (303) 356-9160 TELECOPIER JEFFREY R. BURNS (303) 356-1111 Weld County Department of Planning Services 1400 North 17th Avenue Greeley, CO 80631 Attention: Keith Schuett Re : Wrights Disposal, Inc . USR and CD Application Dear Mr. Schuett : We have determined that the Bull Ditch is owned and managed by Farmers Reservoir and Irrigation Company of 80 South 27th Avenue, Brighton, Colorado 80601 . Very truly yours, LIND, LAWR NCE EN OFF Kenneth F. Lind KFL/cg JAN 73 1994 .,' ill • . WR/A F41r.217 Planning EXHIBIT I ( 1 941079 ' FORT P (lc `° '° tttp of fort lupton to _' :. f,,,,,--; 3s 1 #0 ~ P.O. BOX 148 COUNTY OF WELD 130 S. McKINLEY AVENUE FT. LUPTON, CO 80621 (303)857-6694 Cot MD° January 15, 1994 Department of Planning Services Weld County Administrative Offices 1400 North 17th Avenue Greeley, Colorado 80631 RE: USR-1039 Dear Sirs: The Planning Commission for the City of Fort Lupton reviewed the above mention referral at our regular meeting of January 11, 1994. The Commission recommends approval of the referral with the stipulation that the City of Fort Lupton be notified of any changes. We would also encourage the stipulations on this project be kept consistent with the stipulations attached to the recent Amoco Well agreement. The City of Fort Lupton does not favor the approval of injection wells, but, if approved, the City would appreciate being informed of any future changes. If you have any questions or comments, please let us know. Sincerely, Don D. Stephens Planning Administrator 1 D ql-dgnirat G FEB 0 , 1994 J • EXMilit V if DEPARTMENT OF PLANNING SERVICES PHONE(303)353.3845, EXT. 3540 ,�gr**4t U� �Z -I�� WELD COUNTY ADMINISTRATIVE OFFICES FT'' 1400 N. 17TH AVENUE COMM Ilk GREELEY, COLORADO 80631 • COLORADO Date: December 21, 1993 'JAN 2 4 1994 CASE NUMBER: USR-1039 TO WHOM IT MAY CONCERN: Wwledrearst P1U1 A Enclosed is an application from Wright' s Disposal, Inc. , for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation for an injection well for the disposal of Class I and Class II nonhazardous liquid waste as defined in the Code of Federal Regulations (40 cfr 144.6) in the A (Agricultural) zone district. The parcel of land is approximately 40 acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. The location of the parcel of land for which this application has been submitted is one mile south of State Highway 52 and approximately 1/2 mile east of Weld County Road 19. This application is submitted to you for review and recommendation. Any comments or recommendation you consider relevant to this request would be appreciated. Your prompt reply will help to facilitate the processing of the application and will ensure prompt consideration of your recommendation. Please reply by January 4, 1994, so that we may give full consideration to your recommendation. Please call Keith A. Schuett, Current Planner, if you have any questions about the application. Check the appropriate boxes below and return to our address listed above. 1. We have reviewed this request and find that it does/does not) comply with our Comprehensive Plan for the following reasons . 2. We do not have a Comprehensive Plan, but we feel this request (is/is not) compatible with the interests of our town for the following reasons: 3.Xxx We have reviewed the request and find no conflicts with our interests . 4. A formal recommendation is under consideration and will be submitted to you prior to: 5. Please refer to the enclosed letter. Signed:, (,r Agency: C0LARdoo CA. f, Gas Cows. CO Date: hfl 1p EXHIBIT I ,9- 9 .:10 3 F R THE FARMERS RESERVOIR AND IRRIGATION COMPANY I 80 South 27th Ave. • Brighton, CO 80601 Telephone: 303-659-7373 • FAX 303-659-6077 C i FEB 21994 January 31, 1994 Keith A. Schuett '�Aia"9m-ono:caning Department of Planning Services 1400 N. 17th Avenue Greeley, CO 80631 VIA FAX: 1-351-0978 Re: Case No. USR-1039 Wright's Disposal; , Inc. Dear Mr. Schuett: This letter is to respond to the review of the above noted brine disposal application. If operated correctly, the program does not appear to pose a threat to FRICO's canal. FRICO does not have sufficient expertise to permit it to evaluate the threat of breakdown or escape of brine solution in the shallow aquifers from which it could significantly affect FRICO's interests. We therefore believe that an adequate bond or general liability insurance policy insuring pollution damages should be required as part of the approval . The other aspect of the application is that one of the property boundaries appears to be claimed to the center of the irrigation ditch, describing FRICO's interest as an "easement". FRICO has not made an exhaustive review of its property interests in this area, but FRICO's files do indicate that FRICO owns a fee simple interest for the land underlying its canal in this section. Further, a survey would be required to establish the record property lines in relation to the location of existing structures. To the extent that any overlap of property lines is claimed, FRICO does not agree to include its property in any application. Its response to the above application should not be read to mean that FRICO agrees to the assertion of any specific property or boundary line between its property and its neighbors. �Sii�+ncceerelly, Albert Sack President • EXHIBIT l MEMORAnDUM hiDePlanh Schuett ro Planning p,r, February 15, 1994 COLORADO From Donald Carroll Fu subject: Wright's Disposal, Inc. USR - 1039 I have reviewed the storm-water retention calculations, drawings and memo from Nelson Engineers I had requested on a memo dated December 30, 1993. I have no conflict with the data submitted. On that same memo, I also recommended a designated haul route on WCR 19 and also a road maintenance agreement be entered into with the applicant. The applicant has indicated that the access road is twenty feet wide. This could be a little tight for two-way semi-truck traffic. I would suggest trying to acquire more right-of-way to make this a safe situation. DC/pds:mscheutt5 cc: Commissioner Kirkmeyer File USR-1039 I0 FEB 1 6 1994 j II Manning El EXHIBIT 941.075 RECEI�°EE FEB 11 1994 NELSON ENGINEERS 822 7TH STREET GREELEY, COLORADO 80631 (303) 356-6362 February 3, 1994 Mr. Donald Carroll Weld County Department of Engineering 933 North 11th Avenue Greeley, CO 80631 RE: Wright's Disposal, Project#317 Dear Don: We have completed our analysis of stormwater runoff at the captioned site. The USE BY SPECIAL REVIEW encompasses approximately 37 acres located south of the Bull Ditch in the southeast quarter (SE 1/4) of the northwest quarter (NW 1/4), Section 10, TIN, R67W in Weld County. Approximately 63 acres drain through the subject site to the Bull Ditch; see attached 2000 scale map. Combined with Wright's 37 acres, the drainage basin comprises approximately 100 acres. The historic 5-year flow was determined by using Table 3-A in the Urban Drainage and Flood Control District Volume 1, which related to the hydraulic group indexed in Table 14 of the United States Soil Conservation Services' "Soil Survey& Southern Weld County." The Rational Method, as outlined in Urban Drainage and Flood Control District Volume 1, was used to determine the peak flow and detention pond requirements for a 100-year storm. The attached calculations reveal a negative storage volume for the improvements which are located on approximately 1 acre of the 37-acre site. Therefore, no stormwater detention is required. If there are any questions, please feel free to call me. Very truly yours, SE. LCN/jd Enclosures •9410 773 mEmoRAn®um Keith Schuett To Planning Date DerPmber 30. 1943 COLORADO From flnnnl a csrrnl l Subject: Wright's Disposal Inc. USR - 1039 I have reviewed the application and have the following comments: ACCESS ROAD - The site is located in the center of the section with the access road running out to WCR 19. I have checked the ADT counts on WCR 19 and show a count of 267 vehicles. The count was taken somewhere between WCR 2 and State Highway 52. The applicant is stating under maximum number of users an estimate of 200 vehicles per week. It is estimated that the average weekly user on a year round basis would be 120 trucks delivering per week, and it is also estimated that the lowest usage would be an average of 60 trucks delivering per week. Weld County Engineering Department is 'xecommending a designated haul route be established on WCR 19 and also a` '`oad maintenance agreementtAbe entered into with the applicant. c A new access to the public right-of-way should be constructed using a depth of 4" of aggregate base course and a culvert at the entrance, if required, with flared radius sections. The applicant is indicating that the access road is 20' wide. This could be a little tight for two-way semi-truck traffic. I would suggest trying to acquire a little more right-of-way to make this a safer situation. Tr-STORM-WATER RETENTION - The applicant is indicating there is no storm-water 1 retention. The USR regulations require storm-water retention facilities should be provided on-site which are designed to retain a storm-water runoff for the EVIR full developed site from a 100-year storm. The applicant is indicating a pump house building, an office building, and a concrete pad for an unloading area. These areas would be displacing runoff water. I would like to see a storm drainage report and calculations to prove to me that we do not need a storm water facility. DC/pds:mscheutt cc: Commissioner Baxter File USR-1039 9410'79 , r b � � 00 �� 1/ � ��, � 4Sn f , ( ,� _ /i \-7- ) /ir ©�.. -0c, I 60 A9 �'( I K v� w' —_ ' ' 'Lint 1 ( .)122.-F.. '•A -7 ,, t•t• U/i J7 t NI�i-) 7 -j ,�f/ tkp J / d- �. G asso o��II f 0 3 o � 496 —_ ` T A. , Y3/4 \ Ji il � 0 6/ \' r 1 ° �� C .. ` J/ assn �� ' .. •' o 0 86 ____6: ) .) ) c ,; �l I i\ ,� t r '� .� �� / , , N ° ≤° • I m 1 A � �� l � (� _ '0,` �'_ _ _ w 'S ( �, V A , 5°50 � y0 11 �• . i \,--- ' J/ / II , \ J 0 �� 85 \ 1 Or )C 1 508/ --\ 111 f 1 5051 _... a�C I �\ •\LC2a50 I <960 o a_==__ �° o C �\ s j w ( 1 r) C .0 0 C 05p 5050 % / l a./� evee � '� Ti9I7 15 o 7/.,, ,____ _ , , ________._ _ • 4), 2_1 �� 4'45I 1 m •� 45�> a II/ 5000��/ �� n960(��^ .� _ c°6 �� 11 /I °5 `\ A �� l � • 49]0 � J _J ) C T); % . -006 ( ' f d L&494.5 t , — . = 0 0 s / 0 _ 4945 II 21 L9 ry ,0\x------- 22 r 22 _ --/ --,,,23 23_ Q V CLIENT (AI/79A 74x V • t/�Cn' �- rJO'B}/No.. '{�3 7 7 rT-�I.JBT HERS PROJECT /IU/ //J. CALCULATIONS FORE.I/ /l Cy LLLL.•�^. MADE BY4, y�DATE` / I CKED BY DATE SHEETS__OF /1/STJ/e/C .- . rte Fr/ --)LA-) Ace=-74 /rte /c. s > ,3-O/As �/:'r 1?1.5 y v /C O/crP 05 Tr3G TV/,G fro rr+ J C5 5o/c 5*r/f/E ScTz <th-t/s�� .- -P, ( D fl o w 72&4&43&T 741 i E IS A-U/Z _)eT, `f�J/'✓S - Cf _ %lC2e E7e P 13 >v lc-S c- /7 3 C �,gc/s-ci r. Cfo r-, 72e.f, 7zje /oo x -- / 3 c-is -...� CC. / t Z ZG > _ _ 77 c` S _ s-v 2 r / j 4 G.i1/2O 941079 CLIENT J / 7 JOB NO. 1111A-710' ENGINEERS PROJECT CALCULATIONS FOR //J MADE BY DATE CHECKED BY DATE SHEET ✓ OF V /7f 17/7j22:20 c c) /©0 - y.'. _`>TcTe/4 Trhit kic,i .' 1 /I -r`fc r. ei /rl r/ ' C•. / I-eil j- at -._Jl/ r ; ': erg - Q, ? /Ice e 5 ":'-.'7, a ,.,'kefi 4- it Cam,: Ce r 6 l '`,.( , 791 Att ei 'I n FIJI , 0 aef+ o - 7 7vkr C A ' ia� Ta-fi-i."1/41 • T2.QA . VII 5f arm.. &, /0 t,7 6,/2. / 14- 4,9 Z`73o 71O SL-870 /2o(zl*«--) c.7 /,Zi- /, I 0,7 7 7 / Z 5 73, 4 x 0 ---S ,5 7 S Ne ya AJ-e c- r0- 7 t -Z/t /00 "Rs),-7 7203j, 941078 fib mEmoRAnDum Keith Schuett To Planning Dace March 3. 1994 COLORADO From Drew Scheltinga, County Engineer \.( Donald Carroll ale" Subject: Wright's Disposal Inc. USR - 1039 After talking to the applicants, I visited the facility and have the following comments: The designated haul route should be WCR 19 from the entrance to State HWY 52. It appears to be in good shape except for the north end by the house where it narrows. The access lane from WCR 19 to the facility is a one-way gravel road with good site distance. Visiting with the applicant, they had indicated that if there was a truck coming, one of the trucks would wait until they had cleared the road before the other would enter. This road will not accommodate two-way traffic. The applicant should widen the existing access to 24' for a depth of 100' and construct 50' turning radii onto WCR 19. Based on the present ADT of 267 and the additional average of 120 truck deliveries per week, WCR 19 should be paved. The structural design for an ADT of 267 would be 3" of asphalt and 7" of aggregate base. If an additional 120 trucks per week is added, the pavement design would be 3" of asphalt and 9 1/2" of aggregate base. The additional cost would be approximately $21,500 for the additional 2 1/2" of base. Our recommendation is the applicant enter into an agreement to provide the extra cost of $21,500 and Weld County would pave and base WCR 19 from the entrance to State Hwy 52. cc: Commissioner Kirkmeyer File USR-1039 \ MAR 2 11994 iXM1$tT •144dromp,piagninti 941078 Y-, ,eA'r ,DAs/A, xi1T. 1�V-C/✓. s— "T2n.ti_K tG S'intv6rf1 n 8 nC a n40 H Ir,EM co c,.e/c/enrs o sa-v .OeS/6N Desi6N Q,ES/6N ,4< e e Gk! Le ion . 4154 51 1 ,31- 3" I ,32. CL ,Q1.se /2 7" o.4 q.42 t , t3 a 1 /irA'sw . /D ' O O E1r'/ST, As. go v7 O O T77 L aofi! T AMsrr W.s,A/, Z . I (o 2 4 Y . ( 'Z . z0) ( 2.4s ) r, U E5 G N C '/ 2 . 5 " of EXTRA ,CASE K/G TM or PR o✓&c 7- 1 /V/Lr; F01 2 /Q " of /345E 34 ' vv,ok = 2525 Ton/ 2520 TAJ x •c3,50 = 21, 4 2 . SO 5AI z1, Soo — 941079 /A vim/-4rvr dEs/��✓ ,D.�T.6-x 1i46.4TO4r/ ,F 22 L. A, 1, fr VAR/Ok/rS' D,.siG'/ ,49f/OO.S 7i94fricic /PAN/ /9,4 T 26/7 A-.O.r '° DAY x �o - -412Z- cite 35 93 095 000 , / 4'N 93 -. 0.078 5 u 53 "u. /92, %Z7 /0. 2 Cn4o / 0 • .- P' 1, 0/2- /68 27, Torei4 /007 .. ,40Justee O L.A. t: 4 2 2.a.v-c Cocr.V7 N' /' O. 6O >r Sad = 23 O 4eV, O. Z-A (fan 2 /i4-) Desi‘'v fkirt ya,o 20 yeA,eS ,,G� Cj/Caner/{ / A',r 4 = 6ir°nr,q/c?fl 29. 78 23_O "9,D,J. E,D.t,A x 36S x 29 780..c' fryY "Act?' 26-O,.O1),L- LA-2- _ 34i• Ea L-A ,o.-s/dev7,-4'42o?-ay,) 365# X to yes) a ;+ I. _. 1.4675 /8 'e 20 L0 et,cie d fr,ckf /Jet^/eta•. a t 0 X Zo = I 46,5 5 X zo .= 29.3o 94.1079/77,-c?/77,-c? �e��:..�Cw�.J'i1i,._� �Fl.l) r�G/EK5 = ;4. 7 '�"' 2r'1 , �i� -= �is3 , mEmoRAnDumjj AUG 14994 O 7o Weld County Planning Date "uoM Ceptnty Planning July 28. 1994 COLORADO tpef��fJ/41 From Trevor Jiricek. Supervisor. Environmental Protection Services/ Subject: Case Number: Amended iiSR Name' Wright 's Disposal Environmental Protection Services has reviewed this proposal; the following conditions are recommended to be part of any approval: 1. The facility shall receive only pre-approved (approval from Environmental Protection Agency (E.P.A. ) ) Class I non-hazardous industrial waste and class II waste as defined by the E.P.A. 2. The facility shall monitor groundwater at the site in accordance with the Hepworth-Pawlak Geotechnical, Inc. report on monitoring well installation (attached) , dated July 18, 1994, and the Colorado Department of Public Health and Environment's letter of July 19, 1994, (attached) . 3. Prior to injecting a new class I waste stream, the facility shall provide the E.P.A. Review and Approval Notice (conducted in accordance with) 40 CFR Part 261) to the W.C. Environmental Protection Services. 4. The facility shall maintain compliance with its United States Environmental Protection Agency, Underground injection Control Program Final Permit No. : C01516-2115. 5. The facility shall provide the Environmental Protection Services Division of the Weld County Health Department copies of all audits conducted at the facility. Specifically the audits required twice annually by the E.P.A. shall be submitted. 6. The facility shall provide financial assurance in accordance with Section 1.8 of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities (6 CCR 1007-2) , the financial assurance shall be sufficient to remove all surface structures and any impacted soil, etc. in accordance with the closure plan submitted in the Facility Design and Operation Plan. 7. Prior to pressure testing at the facility, the Weld County Environmental Protection Services Division shall be informed of the specific dates in order to observe the process. 8. Any release of one (1) barrel or more of waste inside or outside of the bermed area shall be immediately reported to the Weld County Health Department Environmental Protection Services and recorded in the facility's operating record. 9. The facility shall have a safe and adequate water supply. The Division recommends contracting with the Central Weld County Water District as indicated in the Design and Operation Plan. 10. An individual sewage disposal system, is required for the proposed facility and shall be installed according to the Weld County Individual Sewage Disposal Regulations. The septic system is required to be designed by a Colorado Registered Professional Engineer according to the Weld County Individual Sewage Disposal Regulations. • EXHIBIT 9 Wright's Disposal Amended USR July 28, 1994 Page 2 11. A manager, knowledgeable in operating an injection well, shall be on site when the facility is receiving waste. 12. A 3-foot by 4-foot sign shall be posted at the entrance gate listing the facility name, hours of operation, and twenty-four hour emergency telephone numbers. 13. The name of the facility at which any waste from the facility is to be disposed, including filters, shall be provided to the Weld County Environmental Protection Services Division. 14. The maximum permissible noise level shall not exceed the industrial limit of 80 dB(A) , as measured according to Section 25-12-102, C.R.S. 15. Fugitive dust shall be controlled on the site. 16. The facility shall not inject more than 5,000 barrels of combined class I & II waste per day. 17. All chemicals stored on-site shall be stored in locked buildings, on an impervious surface, provided manufacturer recommendations for safe storage and handling are in accord. In any event, manufacturer recommendations will take precedence. 18. Any required air emissions permit shall be obtained from the Air Pollution Control Division, Colorado Department of Health. 19. The surfaces around the disposal area shall be constructed of an impervious material and graded to insure that all spilled waste is contained within the unloading pad. 20. The facility shall provide and maintain locking gates at both entrances during periods when the facility is closed. 21. The facility shall comply with the laws, standards, rules and regulations of the Air Quality Control Commission, the Water Quality Control Commission, the Hazardous Materials and Solid Waste Division, the Colorado Oil and Gas Commission, the E.P.A. and any other applicable agency. 22. All construction on the property shall be in accordance with the requirements of the Weld County Building Code Ordinance. 23. Personnel from the Weld County Health Department and Weld County Department of Planning Services shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Development Standards stated herein an all applicable Weld County Regulations. 24. All records required in accordance with E.P.A. , U.I.C. permit No. C01516- 2115 shall be made available upon request to the Weld County Planning and Weld County Health Departments. TJ/lam-2531 941078 mEmoRAnDum wineTo Keith Schuett, Planning Date . ust 25, 1994 COLORADO From Drew Scheltinga, County En.'neer Subject: Wiig1its Disposal, Inc., USR-1039 Attached is a letter from Martin J. Wohnlich, dated August 3, 1994. In his letter he indicates, I assume, an additional 120 trucks per week. He is correct. However, the idea that 120 truck deliveries per week will require 2-1/2 inches of base course is still correct. The extra cost to pave WCR 19 to support 120 trucks is still $21,500. If the applicant is not required to enter into a road maintenance agreement, I recommend they be required to provide dust abatement at the existing house located south of the intersection with State Hwy. 52. I recommend the dust abatement extend 300 feet either direction of any improvements. Also, I recommend a certain level of truck traffic be set that cannot be exceeded unless a road improvements road agreement is reached. The last paragraph on page 3 of the application materials dated December 2, 1993, indicates, "It is estimated that the average weekly use on a year around basis will be 120 truck deliveries per week, and it is also estimated that the lowest usage will be an average of 60 deliveries per week." Therefore, I recommend if there are more than 120 truck deliveries to the site in any one week period the commissioners may require the applicant to enter into a road improvements agreement. Mr. Wolmlich disagrees with our recommendation to widen the access road into the site. We requested the road be widened to 24 feet for a 100 foot depth and 50 foot turning radii be constructed. I think this is a very modest request and the access should be widened for a site that generates 120 trucks per week. DS/zs:wohnlich cc: Commissioner Kirkmeyer Martin J. Wohnlich J � 57 CCcr Planning Referral File USR-1039 ti� AUG 2 1994 _,.,r31an¢aeenA r • IXHIRIT 941079 e Tel: (303) 988.4500 Fax: (303) 988-7962 IGHT'S DISPOSAL INC. 2323 S. Wadsworth, Suite 103, Denver, Colorado 80227 Mr. Drew Scheltinga County Engineer Weld County Engineering Department 933 N. 11th Avenue Greeley, CO 80632-0758 August 3, 1994 Re; Wright's Disposal Dear Drew: Thank you for seeing me on such short notice yesterday. As discussed please find enclosed a graph showing the weekly injection volumes of our disposal well since we started operations in 1989. You will note that starting in July of last year the volumes have dropped very noticeably. Assuming a 100 Bbl load per truck the average traffic to our facility has declined from 140 trucks per week to currently 30 trucks per week. In your memo dated March 3, 1994 addressed to Keith Schuett you assumed an additional 120 trucks per week. We do not anticipate increased traffic when we are a Class I operation. We in fact anticipate a continued low level of traffic and at worst do not see us exceeding the level experienced in early 1993 i.e. 160 trucks per week. Based on the above we do not think that WCR 19 needs to be paved. However, we have been voluntarily treating WCR 19 with dust abatement for the house situated south the intersection with Highway 52. The expense for this dust abatement is $600 per year. Should the decision be made to pave WCR 19 in the future we will contribute $3,000 which represents our dust abatement cost for 5 years. Likewise we do not see the need to widen our access road to 24' for a depth of 100' and construct a 50' turning radii onto WCR 19. As explained above, the traffic is so minor that we have never had any problems with trucks on the access road. I trust the above comments reflect our discussion and please feel free to call if you have any further questions. Sincerely Q /I(/in ld e/.F (ice+ Martin J. Wohnlich 941078 N O N a 01 00 0 N A p1 00 O Mil1 f_ �1 ch i Ol Cr .fie iv .. N ID }� W O C/1 •Z _ O = Z T = -�� . . 3 C.0 W t-a F. O Z • • o or Wm = ►�y O 3 = W a 3 x CO * row = . - , c , CO a = — ED" Iw � . cit d 1 O - _ _� c - f • K CA N • r = 1 , C V .. �' O O �3 • r , Vt f0 L G • 1 0 =• , O r z = ►� T � — T • = • = 3 D CD a = . wa N Z = ' / me , • • • a • 941079 AGREEMENT FOR PURCHASE AND SALE OF REAL ESTATE THIS AGREEMENT FOR TEE PURCHASE AND SALE OF R TATE ("Purchase Agreement") is entered into as of /Z c.' Y 1993 , ( "Effective Date") between SUCZLA FARMS, IN , a Colorado Corporation, ("Seller" ) and WRIGHT' S DISPOSAL, INC. , a Colorado Corporation, ("Purchaser") (and collectively, the "Parties" ) . RECITALS A. Seller presently owns real estate (the "Real Estate") in Weld County, Colorado at 4468 Weld County Road #19 . The Real ! Estate is depicted on Exhibit "A. " Pursuant to a May 16, 1989 General Lease between the Parties, Purchaser currently conducts a business on a portion of the Real Estate, which portion presently contains improvements owned by Purchaser. By the terms of this Purchase Agreement, Seller desires to sell and Purchaser desires to purchase a portion of the Real Estate, including the area in which Purchaser presently conducts its business (the "Property") . The Property is described further, below. In addition, the Parties agree to simultaneously execute an easement (the "Driveway Easement") to Seller over the existing driveway on the Real Estate and a lease (the "Farm Lease") , allowing Seiler to continue farming areas of the Property. The 2arti :s shall also simultaneously execute an agreement terminating the May 16, 1989 General Lease and any other arrangements Between them regarding deep well injection ("Termination Agreement") and shall execute an agreement that settles claims between then ("Settlement Agreement") . The Driveway Easement is de:cribed in Exhibit "B, " and the Farm Lease is contained in Exhibit "C. " The Termination Agreement is contained in Exhibit "D" and the Settlement Agreement is contained in Exhibit "E. " SECTION 1 - PURCHASE AND SALE OF PROPERTY 1.1 Purchase and Sale of Property Subject to the terms and conditions :lereia, Purchaser agrees to purchase and Seller agrees to sell the property described below. 1.2 Property (a) The portion of the Real Estate that is to be conveyed by General Warranty Deed shall be referred t ) as the "Property. " The portion being reconveyed from Purchaser t ; Seller by Grant of Easement shall be referred to as the "Driveway Easement. " The Real Estate retained by the Seller and nc : conveyed by this document shall be referred to as the "Reciaed Property. " (b) Seller retains all right, title and interest to all private water lines which run under Parct II described in + EXHIIIT subsection 1. 2 (d) and, minerals and minerals rights, including oil and gas and other hydrocarbons on or under (with the exception of hydrocarbons produced by Purchaser' s operations) the Property, which is, by this Purchase Agreement, to be transferred to Purchaser, except that Seller does not retain any minerals and • mineral rights within the Lyons Formation. All water, water rights, easements, permits, and rights of way benefitting the Property to be transferred by this Purchase Agreement are to be transferred to Purchaser, subject to subsection 1 . 2 (c) . (Seller will allow Purchaser to hook up to its water line once Purchaser obtains approval from Weld County Central with a separate tap to meter water. ) (c) All right, title and interest to the Property is conveyed subject to certain covenants, restrictions, conditions, and easements ( "Covenants" ) , which are attached hereto as Exhibit "F" and subject to the Driveway Easement and Farm Lease. Purchaser acknowledges and agrees to the Covenants as reasonable and enforceable and fully vested (at closing) . (d) The Property consists of parcels within the Real Estate . The Property consists of approximately 40 . 00 acres and is generally described as follows and is generally depicted as shown on Exhibit E attached: Parcel I The S 1/2 of the E 1/2 of the NW 1/4 of Section 10 , Township 1 North, Range 67 W of the 6th P.M. of Weld County, Colorado, but with the northwesterly boundary to lie instead along the southern edge of the right of way that extends 20 ' above and 20 ' below the center line of the concrete irrigation ditch that runs in a north easterly direction from the western boundary of the northernmost portion of the parcel. Parcel II The North 20 feet of the SW 1/4 of said Section 10 . (e) In the event that Purchaser needs a larger road is order to obtain and/or hold the permits, approvals, etc. to conduct its waste disposal operations as contemplated by this Purchase Agreement, then Purchaser can purchase such additional property from Seller at the rata of $5, 000 per acre. (f) The Driveway Easement shall be a non-exclusive perpetual easement over a portion of the Property as described is Exhibit 3, the use of which shall be for ingress and egress for any reason and for farming activities conducted on the Retained Property. - 2 941073 shall be brought only in the United States District Court for the District of Colorado . 13 . 18 Brokers . Each party represents and warrants that it has not engaged the services of any real estate broker or other agent in the negotiation and/or consummation of this Purchase Agreement and the transactions contemplated hereunder. In. the event that any such broker or agent claims a commission as a result of the actions of either party, such party shall indemnify and hold harmless the other party from and against any and all such claims, as well as the costs of defending against the same. PURCHASER: Wright' s Disposal, Inc. , a Colorado corporation Z/`f/! 7 By: dit% G- Date Martin Wohnlich, President 13 . 19 Notice of Seller Acceptance . If this proposal is accepted by Seller in writing, and Purchaser receives notice of such acceptance on or before 5 : 00 p .m. , Mountain Time, , 1993 , this instrument shall become a contract between Seller and Purchaser and shall inure to the benefit of the legal representatives, successors, and assigns of such Parties . A copy of this instrument may be executed by each party, separately and when each party has executed a copy thereof, such copies taken together shall be deemed to be a full and complete contract between the Parties . 13 .20 {{ Acceptance. Seller accepts the above proposal this 1 day of djae., 1 tQ3 , 1993 . SELLER: Suckle Farms, Inc. , a Colorado corporation '4Zc f 1773 By: `J Date Frank Suckle, President ?GB/31269.1 22 941079 .Ir. 4v ti:40T J, is 'Ln1r 1111 1 i ) il l' • .w y. E -s 1`.�t . N Kai _ ! • 1 . 1 rM 74 Yi"• ‘.:.4.4...,,Z p ' 7 la Ifalti I 6`0'1 '/g",,,,,•44,0 l s. I. y: 1,.. D.. : 1 . n ; ,, w., N `. 61R 3 T,{t s n. •tl M Hsu.:1 !tit ��1 li 111rtnl+• 4 ni " #4,--,,,r-:;;•. t`�5--49-4 ._ .rte to apt w r.• i it o % 114:S;1-4t14± r lry_ ja-j ,6 y' l,:n � :i + ''i i '� .r //Pi• .-.7-' ‘.;..§ ., - �y C ter. • tom l s' (-�"9ti ( "i. 7 1. �,.,.> l f •+.7' '• 1 4 r A l gyxe+ C v'.• ' • 4 ; l ''. .- �: c , fr 9, . .a` a1S.. 1; 1.[•. :. yi r fr• �l; ?. 1. ,,,i..- Z_ I, ,: . ;„„• Q+ ' _ .te.„., {1 -1l ..\ ......„,.., 'l ir' :.1� Ce rU,t 1. ann ,E7HIY�'�;?.fE`r72•v n : ;T:tr_ ,, ,+e• '; E2BIBIT A SWAMP The S 1/2 of the S L/2 of the NW 1/4 Section 10, Township 1 North, Range 67 W of the 6th P .M. of Weld County, Colorado, but with the northwesterly boundary to lie instead along the southern edge of the right of way that extends 20 ' above and 20 ' below the center line of the concrete irrigation ditch that runs in a north easterly direction from the western boundary of the northernmost portion of the parcel . i 'The North 20 feet of the SW 1/4- of said Section 10 . , I- 941078 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LAW BUILDING 1011 ELEVENTH AVENUE P.O. BOX 326 GREELEY, COLORADO 80632 GEORGE H. OTTENHOFF TELEPHONE KENNETH F. LIND (303) 353-2323 KIM R. LAWRENCE (303) 356-9160 TELECOPIER JEFFREY R. BURNS (303) 356-1111 December 15, 1993 O U1r1tV L� Weld County Department of Planning Services 1400 N. 17th Avenue DEC I 1993 Greeley, CO 80631 ATTENTION KEITH SCHUETT Weld Co pl °E RE: USR & CD Application of Wright' s Disposal, Inc. Dear Mr. Schuett: Pursuant to your telephone call of December 15, 1993 relating to your concerns with the authority of Wright's Disposal pursuant to its General Lease with Suckla Farms to submit the Application, enclosed for your reference are 25 copies of four pages from a lengthy and detailed Agreement for Purchase and Sale of Real Estate dated December 9, 1993 between Suckla Farms, Inc. and Wright's Disposal, Inc. Pages 1 and 2 of the enclosed Agreement specifically refer to the May 16, 1989 General Lease between Suckla and Wright's, the litigation between the parties and other items. You will note that this Agreement describes 40 acres of land to be sold to Wright's Disposal by Suckla Farms and it indicates that the 40 acres parcel includes the area in which Purchaser conducts its business. This Contract shows the interest of Wright' s Disposal in and to the subject property which gives them the total authority to submit the USR and CD Application. As to your question regarding the authority of the undersigned to submit the USR and CD, please be advised that the undersigned is an attorney authorized to practice law in the State of Colorado, the authority being granted by the Supreme Court of the State of Colorado. The undersigned is licensed to practice in the State of Colorado, is an attorney, and as an attorney, does not need to have a "Power of Attorney" to represent clients. As a matter of principle, the undersigned respectfully declines to submit a "Power of Attorney" , instead the undersigned will rely upon his authority 4 • EXHIBIT Steil and licensing as an attorney in the State of Colorado to submit this Application. Very truly yours, LIND, LAWRENCE & 19 T-7 FF Kenneth F./land KFL/sef Enclosures pc: Lee Morrison Wright' s Disposal, Inc. 941073 12/18/93 11:05 $303 356 1111 THE LAW BUILDING 002/002 02-24 '00 04:34 ID:LAN: 'AX3800 FAX: PAGE 2 GABLEHOUSE&EPEL A law numaMWTI►M 1'K,rMwnx,I.Cal muArwNS 10.10 SEVENTEENTH STnE.rr 0108)flCo50 $LTITX 17A0 FAX(anl)ET10037 I)EN VEE.COLAINDO 80788 MIA_EDecember 15, 1993 Kenneth F. Lind, Esq. Lind, Lawrence C Ottenhoff 1011 Eleventh Avenue P.O. Box 326 Greeley, CO S0632 Re: Wright's Disposal's Application for Use by Special Review and Certificate of Designation Peer Ken: Pursuant to the final Purchase Agreement signed on December 9, 1993 by Suckle Farms, Inc. end Wright's Disposal Inc. , Suckle Farms has no objections to Wright's Disposal Inc. 's submittal of its Application for Use by Special Review and Certiftoots of Designation for disposal by injection of Class I and Class II nonhazardous liquid waste.Sincerely, s D 5D12\v/(��r ABLeHOUSs 65Psrta DEC 1 6 1993 • S r_, Weld County Planning ar na M. Thomas ' KMT/kt pc Frank a Edith Suckle Dean a Carolyn Faulkner IXEXPIIIIIT PRINTED ON1unnshrAPee DEC 16 '93 11:04 I 303 356 1111 PAGE.002 941079 12/16/95 11:05 22303 556 1111 THE LAW BUILDING U001/002 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LW mm.aNO bII RL1Ve'!n)AVENUE R 0.ROX 326 OREx1EY,COLORADO 616)1 GEORGE H.O IUIICFF TELEPHONE KENNETH F.LINO OW))5}011 CM a ueRENrs IMPORTANT TELECOPY NOTICE p°))) CLUDNU Cm))561111 COVER SHEET DATE: /,2/Lee /9,3 TIME: I 0 D A.n TOTAL NUMBER OF /PAGES (INCLUDING COVER SHEET) : ya TO: /iJi Id l nitn / (141)717/5 t o f7 ATTENTION: '1( /1 �1 rhu17 T (/ TELECOPIER NUMBER: ( ) 3 5] - d 9 7/ FROM: LIND, LAWRENCE & OTTENHOFF (KENNETH F. LIND) TELECOPIER NUMBER: (303) 356-1111 / COMMENTS: en Jet 1/n Gf C inLi7a hnt IF YOU DO NOT RECEIVE ALL_,PAGES OR EXPERIENCE ANY DIFFICULTY WITH TRANSMISSION, PLEASE CONTACT CINDY AT ( 303 ) 353-2323 . _ CONFIDENTIALITY NOTICE This facsimile transmission contains Information belonging to the sender which Is confidential and legally prlvlledged. This Information is only for the use of the Individual or entity to whom It was sent as indicated above. If you are not the Intended recipient, any disclosure, copying, distribution,or action taken in reliance on the contents of the information Is strictly prohibited. If you have received this transmission in error, please call us collect to arrange for its return to us at our expense. Thank you, DEC 16 '93 11:04 303 356 1111 PAGE.001 941078 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LAW BUILDING toll ELEVENTH AVENUE P.O. BOX 326 GREELEY. COLORADO 80632 GEORGE H. OTTENHOFF TELEPHONE KENNETH F. LIND KIM R. LAWRENCE (303) 7s3-2327 December 20, 1993 307) 3569160 JEFFREY R. BURNS TELECOPIER (303) 356-1111 Weld County Department of Planning Services 1400 North 17th Avenue Greeley, CO 80631 Attention : Keith Schuett Re : Wrights Disposal, Inc . USR and CD Application Dear Mr. Schuett : On December 16 , 1993 you contacted me requesting some additional information regarding the above referenced application. Hereinbelow are your questions and/or, comments and responses . 1 . Question or Comment : Page 2 of the application letter dated December 2 , 1993 made reference to a May 9 , 1989 letter from Weld County and said May 9 , 1989 letter was not included in the application materials . Response : Attached to this letter is a copy of said May 9 , 1989 letter. 2 . Question or Comment : The $10 . 00 USR recording plat fee check was not enclosed. Response: Attached to this letter is our check in the amount of $10 . 00 payable to Weld County Department of Planning Services . 3 . Question or Comment: The vicinity map showed, by a hatched line, access to the USR site from Weld County Road 19 but the plan map did not include the access road in dark lining. Is the access road to be part of the USR area? Response: The USR area will be approximately 40 acres which will include the access road. At the present time it is contemplated that said access road will only need to be 20 ' in width. If the access road needs to be larger for any reason, the applicant and the current owner of the property, Suckla Farms , Inc . , have agreed that the applicant can acquire additional property to widen the access road. The exact parcel configuration including access road will be delineated and plotted by metes and bounds description upon final approval , and prior to recordin- - the Use by Special Review map . IglT EXN • u 07S Weld County Department of Planning Services December 20, 1993 Page 2 4 . Question or Comment : The application discusses a retaining structure around the tanks for purposes of confining any spill . What is the total capacity of the area within the retaining walls? Response: The EPA has approved 9 holding tanks with the largest tank having a capacity of 400 barrels . The concrete retaining wall encloses all 9 tanks and will hold 431 barrels . It was required that the retaining wall be of sufficient capacity to hold all fluid from the largest holding tank. 5 . Question or Comment : The USR parcel is 40 acres in size but the actual operations and business area is less than 3 acres in size . What is the current use of the balance of the property and what is contemplated for future use? Response : The 40 acre parcel will consist of approximately 1/2 acre for access road, 3 acres for the operational site and the balance of the property being approximately 36 . 5 acres is currently used for dryland agricultural production. The future use will remain the same as the applicant and current property owner, Suckla Farms, Inc . , have entered into a lease providing for farming of the acreage not used for the active operational site and road. 6 . Question or Comment: The application did not address noise . Are motors on site electric, gas, diesel or other? Response : All on site motors are electric with the only main source of noise coming from the 24 ' x 24' pump building. This is a totally enclosed building which has a door that can be opened on the East side of the building. The nearest residence (Suckla) is not bothered by any noise emanating from the pump building and this noise can be controlled by closing the door. The other source of possible noise is entry and exit of trucks to the operational site . The applicant will comply with all applicable State and/or Federal noise and sound restrictions for this type of use . 7 . Question or Comment: Do we have an address for the Bull Ditch which runs through the property? Response : As of the date of this letter we have not yet determined an address for the Bull Ditch. The applicant is checking with neighbors to determine responsible parties and/or addresses which will be provided to the County as soon as possible . 8 . Question or Comment : What are the plans for parking for employees and/or users of the facility? Response: Employee parking is located within the area bordered by the tank facilities on the West, the 24 ' x 24 ' pump building on the North, the facility entrance from the road on the South, and the 10 ' x 16' office building on the East . The employee 941079 Weld County Department of Planning Services December 20 , 1993 Page 3 parking area is approximately 30 ' x 30 ' . Other "parking" takes place at the South end of the facility on the 11 . 6 ' x 60 ' cement pad which is the truck unloading area . This is no actually parking but is used for truck unloading but the vehicles are parked during unloading. Also enclosed is a copy of the United States Environmental Protection Agency Minor Permit Modification which provides for an increase in injection pressure . This minor permit modification is considered an addendum to the EPA approval . Should you have any additional questions or comments, please feel free to contact the undersigned. We are enclosing the original plus 27 copies of this response for your use . Very truly yours, LIND, LP,WRENCE / TTENHOFF , / i Kenneth F. Lind KFL/cg Enclosure 941079 f „ `.., CE?An- .:NT CF. TLANNING $ERVic7-3 v a j . J �- .t PHONE i]011 ]�6-+CO0 FrasCC FF r 0L lCtn O 406:2: 06: GRE_l.cY,COLORADO dC6J7 • wilic COLORADO May 9 , 1989 A & W Water Service , Iac . Attn: :!r. Charles Wright P .O. Box 446 Brighton, CO 80601 Legal Description: ?art of the SEi NEi of Section 10, T1H. R67W of the 6th P.H. , Weld County, Colorado. Dear :'r. Wright: This letter is co inform you chat the Department of Planning Services has determined that an injection storage facility for the disposal of well water by trucks existed before August 30, 1982 , zoning of your property. Therefore, we have determined that the injection facility for the disposal of brine water by trucks is a nonconforming use. Nonconforming use number NCU—Z1y has been assigned to thu file. Please retain this number for further reference. Production water disposal through either secondary recovery or deep well disposal methods and the mode o£ transport to such injection wells, i.e. . exclusively via pipeline is defined as a use by right in the A (Agricultural) zone district. Should the present use change in any way, it would need to comply with the present zoning ordinance. • We want to thank you for your cooperation in this matter. • Sincerely. le Curt t Planner • B:TB:r j g • • 900x.?') . .. . .. 941079 NONC: .,?rp:-•Irri CS: FAr__ e_'_. Y.C.ti.G'L7 Nate (Cvrar) A Water Service, Inc. Address: P.C. Box 446 3righcoa, CO 80601 Phone No. . 659-6523 LEGAL DESCRI?TION: Part of the SE: NEI of Section 10. TIN, R67W of the 6th F.N. , Weld County, Colorado LOCATION: Apprositacely Z miles vast of the City of Fort Lupton; south of State Highway 51 and vest of Weld County Road 11 USE OF PROPERIT: At infection storage facility for the disposal of brine crater by truck. Used on arc annual figure. traffic to the site averages 9.47 trick trips per day. These calculations were obtained fron the AMOCO Froduction Company accounts receivable sheets for 1986 and 1987. • CURRENT ZONING: A (Agricultural) APFROPRIATz DATE FOR DETERMINATION OF NONCONFORMING USE: January 5, 1977 - Use by tight it the A. (Agricultural) zone district_ August 30. 1982 - Ordinance 89-3. Cse by Special leviev_ REASONS FOR DETERMINATION OF NONCONFORMING USE: Records o£ AMOCC Production Company accounts receivable records indicate the use of the storage facility for ia+ection as early as L97$_ Adoption of Ordinance 89-3, August 30, 1982. establishing infect-tom veils as a Use by SpeciaL Review La the A (Agricultural) zone district- l ‘�, _ - • s©0.4420 - • - w_ 9410'79 22-:993 :@= :2nr ==CM 5o'- G �Ratik. ' UNITED`STA" ; ENVIRONMENTAL PROTECTI( AGENCY I's .irk 1 REGION VIII iii ; 949 18th STREET • SUITE 500 DENVER, COLORADO 80202-2466 DEC 6 1993 Ref : 8WM-DW CERTIFIED MAIL RETURN RECEIPT REOUESTED Martin J. Wohnlich • wright' s Disposal, Inc. , 2323 South Wadsworth, Suite 103 ' Denver, Colorado 80227 / , ' RE: UNDERGROUND INJECTION -CONTROL ( JIC) Minor Permit Modification for tie Class I Suckla Farms #1 Well (EPA Permit #C01516-02115) Weld County, Colorado Dear Mr. Wohnlich: Enclosed is a minor modification to the above-referenced permit. Your 'request to increase the maximum surface injection pressure was received in our office on September .l0.;, .1993 . The results-of a step-rate test performed in the Suckla>=Farms #1 well support your request for an adjustment in inject4'om. pressure; therefore, your request has been approved. The enclosed "Addendum to Statement of Basis.° discusses the reasons for the'.permit modification and the upward,:adjustment of injection pressure from 2, 397 pounds per square ' inchgauge (psig) to a maximum of 3 , 700 psig. If you have; any questions on this action,' you may contact ,) John Carson at (303). 293-1435 . Also, ?lease direct4al1 corresnondence-t the attention of John Carson. at42.ail` Code 8wM-Dw- • Sincerely, Do Director Wa r Management .Division Enclosures: Addendum to Statement of Basis Minor Permit Modification Printed on Recycled Paper 941079 :2-20- :2 :2P =<C(" R 3 t TO 13561111 P.04 tr • Martin J. Wohnlich Wright' s Disposal/ Inc. CO1516-02115 4 Page 2 • cc: Glenn F. Mallory w/enclosures Colorado Department of F:ealth John S. Pickle w/enclosures Weld, County." Health Department , J' . • Ken Merefeider Wright' s Disposal, Inc. • • • • 941079 12-a-_S53 _2: .2;^' & R TO 13561111 P.05 J'®Ve. • UNITED STAI 4 ENVIRONMENTAL PROTECTIL.. AGENCY Lir 7 tait REGION VIII 999 18th STREET - SUITE 500 nor DENVER. COLORADO 80202-2466 • MINOR PERMIT MODIFICATION Class I Well Suckla Farms #1 EPA Permit #C01516-02115 Pursuant to Part III, Section B. 1. of the above-referenced • Class I Underground Injection Control (UIC) permit, .a modification to 'said permit is to be made. Changes to the original version of Part II, Section C. 4. (a) are as follows: Original version:. • ' 4 . Injection Pressure Limitation. (a) Injection pressure, measured at the surface, shall not exceed 2, 397 pounds per square inch gauge. — Is Modified to read: 4. Injection Pressure Limitation. J (a) Injection pressure, measured at the surface, shall rot exceed 3 , 700 pounds per square inch. gauge. All other provisions and conditions of the final. permit for the Suckla Farms #1 well remain as originally issued. December 3, 1993 Date / Dodso , 'Director ,. Wat Management Division EPA Permit #CO1516-02115 Page 1 of 1 • • Hinted on Recw/UA P410763 a �SS 'e: :,.;Rr --Cr ` `0 13561111 P.06 • • • • .1 Addendum to Statement of Basis • for EPA Permit #C01516-02115 Class I Well Suckla Farms #1 . Date prepared 10/8/93 Wright's Disposal, Inc. submitted a request for a minor permit modification on September 10, 1993 . The request was to increase the maximum permitted surface injection pressure. from 2, 397 pounds perasquare inch gauge (psig) to 3, 7.QOrpszg.;. based on the results of-a -step-rate test os° the Lyons injection zone • • (9,276-9, 418 feet) in the Suckla Farms #1 disposal well. Injection Pressure: A review of data from a step-rate test performed on • • July 9 , 1993, indicates that no fcrmation breakdown of the Lyons occurred up to the termination of the test at a surface injection of 3, 700 psig at an. injection rate of 8. 0 barrels ofwater per minute. This surface injection pz :ssure, adjusted for ' . hydrostatic. pressure and friction ".oss in the tubingcstring, corresponds: to a`'bottom-hole pressure of 4, 515 psig? . 'Subsequent to the step-rate-test, a temperate e log and a radioactive tracer survey were run in the well during injection. Both tests indicated that all fluids were ent .•ring and being contained in the injection zone. Under Part II, Section C. 4. of the permit, the injection' pressure may be increased by the Director if the permittee demonstrates that: the proposed increase in surface injection pressure..will. not. exceed the injection formation fracture pressure. The' p;essure limit is to be deterMinet byrlperforming a step rate test`or.- other authorized well test(s) . ':.Therefore., on • the basis of the?`test results, a maximum surfaceinj'e.ction pressure of 3, 700 psig shall be approved for the Suckla Farms #1. EPA Permit #C0151.6-02115 Page 1 of 2 941076 rR 70 13561111 P.07 j . • Suckle Farms Iniecfion Well #1 Wright's Disposal, Inc. - CO1516-02115 • 4000 3500 • Figure 1 . Q 3000 Step Ratf Injection Test f •c-2500 2000 . < 1500 • 1000- 500- . • 00 . 1 2 3 4 5' 6 7 8 . RATE (bbi/mir • • • • • u • EPA Permit CO1S16-02115 941.0'79 • . .. .norm 1 elf .7 0 D, LAWRENCE & OTTENHOFF JAN 1 3 1994 ATTORNEYS AT LAW -- u THE LAW BUILDING Weld County Planning 1011 ELEVENTH AVENUE P.O. BOX 326 GREELEY, COLORADO 80632 GEORGE H. O'ITENHOFF TELEPHONE KENNETH F. LIND January 5, 1994 (303) 353-2323 RIM R LAWRENCE (303) 356-9160 TELECOPIER JEFFREY R. BURNS (303) 356-1111 Weld County Department of Health r:15- 5 Ic�ycp 1517 16th Avenue Court r' r i /r a Greeley, Co 80631 Obr JAN 21'1994 ! " Attention: John Pickle, Director Re : Wrights Disposal, Inc. Dear Mr. Pickle : On Tuesday, December 14, 1993 our office, on behalf of Wright' s Disposal, Inc. , submitted an application for Use by Special Review and Certificate of Designation to the Weld County Department of Planning Services. The Planning Department commenced processing the materials and on or about December 21, 1993 referral packets were mailed out . We presume that the Health Department has received a referral packet but if you do not have one or need an additional copy, please contact the undersigned and we will make sure that you immediately receive one . I would also advise you that as of this date no schedule has been established for any hearings with the Planning Commission or Board of County Commissioners . It is our expectation that the State Health Department will finish its review within the next 90 days and we are hopeful that the hearing process can commence immediately thereafter. As you are aware, the facility currently is authorized and approved as a facility for injection of oil and gas brine water under the authority of the State of Colorado Oil and Gas Conservation Commission, also frequently known as A Class II permitted facility. The facility has also gone through a very lengthy and detailed review and permitting procedure by the Environmental Protection Agency which has approved the facility as an approved operation for injection of non-hazardous Class I fluids . Even though the facility has received Class I EPA approval, there is some basis to believe that both Weld County as well as the State of Colorado may have some jurisdiction to review certain operations of the facility and that is the reason the applicant has applied for the USR and Certificate of Designation approval . As you are familiar with the facility and its existing operations, we can confirm that the existing permitted facility can inject up to 3 , 000 barrels per day of Class II brine water. The current operation has been receiving and injecting up to 3 , 000 barrels per day on an ongoing basis . IEXHIBIT �� 941079 Weld County Health Department January 5, 1994 Page 2 With the EPA approval of the facility as a non-hazardous Class I injection operation, Wrights Disposal also received specific approval and authorization from the EPA to inject another type of brine fluid which is brine water from the Monfort packing plant at Greeley which is waste water from hide washing operations. This fluid is very similar to oil and gas brine water and we have enclosed a laboratory report of the hide brine water. The purpose of this letter is to request temporary approval to allow injection of the hide brine water in addition to oil and gas brine water. We understand that this approval would only be temporary, would be limited to injection of the hide brine water (in addition to oil and gas brine water) and no increase in the permitted injection levels of 3, 000 barrels per day would be authorized. The 3, 000 barrel per day limit would still be in effect which means that Wrights Disposal would reduce injection of oil and gas brine water to allow for injection of the hide brine water. As there would be no increase in the amount of injection fluids, there would be no increase in traffic or any other change of operation. I -would also advise you that the current owner_of — -- - the surface, Sucklas Farms Inc. , has approved this request for temporary operations .--------- There is no question that the injection of the hide brine water would be of significant benefit to the agricultural community of Weld County and we would request your temporary approval . It is our understanding that you will review this request and, it is meets your approval, you will then request a work session with the Board of County Commissioners. I believe that we have provided to you all information but if you need any additional information or clarification of any questions, please contact the undersigned. We thank you for your cooperation and consideration. Very truly yours, LIND, LAWRE CE TTENHOFF n X Kennet F. ind KFL/cg Enclosure pc : Jeff Stoll, Weld County Health Department Lee Morrison, Assistant County Attorney Wrights Disposal Wes Potter 9410'73 PAR HOT SHOT INC TEL :1-303-426-8911 Sep ?9 .93 15 : 15 Ma .001 P .02 sE�.�3 'y3 9:30 FROM MONFORT 303393231i Wes PoStk enVice Presidentwoo805.32 E^ n+rentalOPeradons . anon Once Y aios - ® ra Red M aw ( 3s,1.23r '0330 Meat Companies PPorate Offices m PROtt: 0. Box 6 Grime): Colorado 80532 DATE: 2t 4' 3 • • FACSIMILE NUMBER:t 303-353-8988 . _ WE AVE OF PAGES TO SEND POTTER, AT ANY PAGE. PI?ASEN� CDSNG TNZS p2lGE. WE .fl ASSUME YOU RAVE E 42 CAL 193 353-2311 AND Jgc2. RNEED CEI HI NEB / �T�87'ACTO TES. nr YOU DO CALL,- PLEASE DELIVER TO: 0447 • la r t/l / SPECIAL INSTRUCTIONS t � r 4,4 THANE YOU. 45 Per IIe5- % We, • • • 941079 R&R. HOT SHOT INC TEL :1-303-4I?6-8911 Sep 29.93 15:16 No .001 P.03 SOP c3 ' :ti's Z:4] h 1 I•ILNF0NT r133J&:J1l F•Htih . Yn1Y IARv2 293 13I0a F, •1 n0NF0RT 3033332311 1+AGG.003 • • i Warren Analytical Warren Analyticala 81o1op kale I.O.8w1G & Biologicals ISO V Street Grady,Colorado 80632.0350 140041454669 2-•ABORATORY REPORT • Atttii was POTTER, Pog•• T GRBELGY PACKING SEWAGE T, Work Order No. 932361 Fri.:TERED BRINE WATER ' Receive Date; 03/11/89 Rspertsd: 09/12/93 Sapls Oat.: .i-lb-93 SPATE SOOIT11T0A17OA ME 1.0. s2/10/u PTLnm , tun OATEN SATO nun ...--.__ __.. .TOTAL sOs1EAOEi WW11.0 TOTAL RIROFd satin 210,sss M7 PR TOTAL UMIAK i 1St fl ABC1SIA-2 • 110 111 ATTACH 1.= RAI • • 7 .. .... f • • • • • • C � Quick supervioer Gpeoi«T Protects • 94107!9 • if 0.0 OFFICE OF COUNTY ATTORNEY JAN 2 6 1994 PHONE(303)356-4000 EXT. 4391 P.O. BOX 1948 GREELEY, COLORADO 80632 WI I ,rein rffint.Planning C. January 25, 1994 COLORADO Ken Lind Attorney at Law P.O. Box 326 1011 11th Avenue Greeley, CO 80632 RE : Wrights Disposal Dear Mr. Lind: The Board and Planning and Health Departments have received your letter requesting interim authority to accept certain wastes to the Wrights Water Disposal facility. You have requested a work session to discuss the authority and this letter is to advise you that it is, in my opinion, inappropriate for a work session to take place on this issue with your clients presenting evidence to the Board of County Commissioners when there is a pending hearing on substantially the same issues as would be discussed in the work session. A work session without full public notice as is required in the public hearing jeopardizes any decision the Board might make on the case in chief particularly if it is ultimately in your clients favor. I have recommended to the Board that they consider your request and I am asking if you have any additional written materials you wish to submit to the Board that then would also be submitted into the record and available for public review. In particular, I am interested in any written materials you may have from the generator of the waste which may support your request that an interim approval would be granted, at your clients sole risk, to accept the waste prior to the decision on the Certificate of Designation and Use by Special Review. Thank you for your attention in this matter. Yours truly,( A��qeer D. Morrison Assistant Weld County Attorney LDM/db i EXHIBIT pc : Board of County Commissioners Planning Department Health Department STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH Dedicated to protecting and improving the health and environment of the people of Colorado %task 4300 Cherry Creek Dr.S. Laboratory Building Ie7s• Denver,Colorado 80222-1530 4210 E.11th Avenue Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 Roy Romer Governor January 27, 1994 Patricia A.Nolan,MD,MPH Executive Director Mr. Kenneth F. Lind Lind, Lawrence, and Ottenhoff P. O. Box 326 Greeley, Colorado 80632 RE: Certificate of Designation Application Thirty Day Completeness Review Wright's Disposal, Inc. Liquid Waste Impoundment Weld County, Colorado Dear Mr. Lind: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has received Wright's Disposal, Inc.'s application for a Certificate of Designation, dated December 2, 1993 for an underground injection well liquid waste disposal impoundment. This application was received in our offices on December 27, 1993. In accordance with the solid waste statute, C.R.S. 30-20-100.5, et seq., and with the regulations promulgated thereunder (6 CCR 1007-2) (the Regulations), a preliminary completeness review of such applications is required within 30 days of receipt. The Division has completed its initial review of the application. Based on that review, the application is complete. The Division will therefore commence its formal technical review of the application. The technical review is mandated to be completed within 150 days of the notification of completion of the initial review. Please note that it is not the intent or purpose of the initial completeness review to imply anything concerning the final approval of a proposed facility. Also, to facilitate the technical review, the Division may request additional information in order to clarify aspects of the proposal. If you have any questions or need any further information, please call me at (303) 692-3462. Sincerely, Steph n La eman 1 ppg f Geological Engineer "u Solid Waste Section j FEB 2 1994 Hazardous Materials and Waste Management Division Pawn Planning cc: Martin Wohlnich, Wright's Disposal, Inc. Trevor Jiricek, Weld County Department of Health Keith Schuett, Weld County Department of Planning Services i EXHIBIT John Carson, United States Environmental Protection Agency 33 File: SW/WLD/WRI/2 " Ids LIND, LAWRENCE & OTTENH ATTORNEYS AT LAW THE LAW BUILDING FEB 0 9 1994 11 1011 ELEVENTH AVENUE P.O. Box 326 GREELEY, COLORADO 80632 "IWOonwo.trplanning GEORGE II. OTTENIIOFP TEI,f;PIIONR KENNEIlI F. LIND (3071 351-2323 KIM R. LAWRENCE February 8, 1994 (303) 356.0160 TRLECOPIER JEFFREY R. BURNS (903) 356-1111 Lee Morrison Assistant Weld County Attorney P.O. Box 1948 Greeley, CO 80632 Re : Wrights Disposal Dear Mr. Morrison: Pursuant to your letter dated January 25, 1994 , we are submitting additional written documentation to support the request of Wrights Disposal , Inc . for interim authority to accept hide brine waste water produced from the Con Agra Greeley plant . Enclosed is a letter dated February 7, 1994 from Edward Lee, Environmental Projects Coordinator of Con Agra which is marked Attachment "A" and gives a more specific description of the hide brine water. Enclosed as Attachment "B" are copies of two letters, the first being to the State of Wyoming from Mr. Wes Potter which is a request to dispose of the hide brine water and the second is a letter dated March 18 , 1993 from the Bureau of Land Management granting approval to dispose of the brine water until March 15 , 1994 . (Approval of the BLM was necessary as the disposal site is located on Federal land) . The third enclosure, marked attachment "C" , is written confirmation from John Carson of the Denver office, Environmental Protection Agency dated July 26 , 1993 indicating that the EPA had approved the hide waste water for disposal at the Wright Disposal site in Weld County, Colorado. Also enclosed as Attachment "D" is a letter dated September 3 , 1993 from the United States Environmental Protection Agency. The first paragraph of this letter concerns testing information and the second paragraph is a formal confirmation that the EPA has approved the hide brine water from the Greeley plant for injection at the Weld County site . As the hide brine water has been tested on more than one occasion and reviewed by Federal authorities, including the Environmental Protection Agency regional office in Denver, there is no question that the hide brine water is a very acceptable product for injection and is definitely considered to be less .of a "problem" than oil and gas production water. As the approval for disposal in Wyoming expires March 15, 1994 , there is some urgency for review and approval . It should also be noted that the disposal a EXHIBIT NC Lee Morrison Assistant Weld County Attorney February 8, 1994 Page 2 of the fluids in Wyoming is extremely expensive which does have significant impacts related to the Greeley plant . It should also be noted that a hearing on the CD and USR application of Wrights Disposal has not been scheduled, in fact, in a letter dated January 27, 1994 we were informed by the Colorado Department of Health that the technical review will take approximately 150 days after January 27, 1994 . Due to the required County hearings it is entirely feasible that this cannot be formally reviewed by the Board of County Commissioners until the fall of 1994 . Due to the timing involved and the nature of the hide brine water, we believe that interim approval is proper. Thank you very much for your attention and consideration. Very truly yours, LIND, LAWRyNCE & OTTENHOFF KenfiLi KFL/cg Enclosure pc : Weld County Department of Health Weld County Planning Department Wrights Disposal , Inc. 941079 Post Office Box "G" ° Greeley, Colorado 80632-0350 �s,"(1fl Phone: (303) 353-2311 Age Red Meat Companies February 7 , 1994 Board of County Commissioners P.O. Box 1948 Greeley, CO 80632 RE: Wright's Disposal Well In reference to your request for more information and detail on the brine waste we propose to dispose of into Wright's Disposal Well located in Weld County, Colorado, I offer the following. The hides from the Monfort's Greeley Beef Plant must be preserved and stabilized for storage and shipment to tanneries . The hide itself has little difference to fresh meat in its ability to spoil and deteriorate quickly without preservation. The vast majority of the tanneries are located in Pacific Rim countries , Japan, Taiwan , South Korea and others. The vast distances and the times involved require effective preservation. The most common and cost effective method of preservation of these hides is through the use of salt, Sodium Chloride, the same compound as ordinary table salt. This method has been used for centuries and is the method used at the Greeley Plant as well as and all others in ConAgra Red Meat Co's . The salt used at Greeley comes from the Salt Lake City area of Utah and is of the same quality used for table salt. After the hides are removed from the animal they are cooled and passed through a machine called a flesher to remove the remaining fat and flesh from the inside of the hide. At this time the hide contains approximately 80% moisture and no salt. The hides are transported to the hidehouse by truck and placed into raceways which are concrete tanks with paddles for complete continuous mixing. The raceways contain the brine made up of a saturated solution of salt. This solution is 24% salt by weight. Over a period of about 24 hours the moisture contained in the hides is mixed with and replaced with the brine . This process dilutes the original brine below the saturation point. It is then necessary to add more dry salt to the raceways to bring the brine back to a saturated solution before the process is completed. This process causes an increase in the volume of brine in the raceway because of the moisture contained in the fresh hide. Each day a volume of the brine must be removed from the raceway and disposed of. The volume to be disposed of is about one gallon per hide processed. The :+ .,i '.- ATTACHMENT „A" 941,1079- hides are then removed from the raceways, passed through rollers to remove excess brine, a small amount of dry salt sprinkled on by hand, folded neatly and packed onto pallets for shipment. The hides will keep a long time as long as moisture is prevented from coming in contact with them. Chemical analyses of the excess brine to be disposed of is, salt of 24%+, organic matter of 1% or less, fat of animal •origin 100 ppm or less , and a BOD of 5 , 000 to 10 , 000 parts per million . There are no Petroleum Hydrocarbons present. The brine is a light tan in color with little odor other than of salt and animal hides . From the raceway the brine is screened to remove hair and any other large particles , then passed through a 100 micron filter to remove very small particles . A micron is one thousandth of a millimeter, the filter size would be 0 .0039 inch or 3 . 9 thousandths . This is suitable for injection into a disposal well. This is a very consistent liquid varying seasonally only in the organic content due to the cleanliness of the incoming cattle. The 1% organic matter is an average of the year with levels varying from less than 0 . 5% in summer to 1 . 5% in the winter. The saturated brine inhibits nearly all bacterial growth in the brine thus this liquid does not become odorous during storage or transport, or during unloading and injection into a well . Transport of the brine is with standard tanker trucks that are closed and essentially sealed and thus liquid or vapors are not emitted during transport. There are no sulfur compounds contained in the brine to be biologically converted into noxious odors unlike the brine from the Petroleum fields . The brine will not freeze due to the salt concentration and it contains no hazardous chemicals. Sin erely, (!/% Edward A. Lee Environmental Projects Coordinator Environmental Operations ConAgra Red Meat Co's P.O. Box G Greeley, CO 80632 cc: Ken Lind-Attorney Wes Potter-V.P. Env. Ops . 9410'7'9 • gNr OF At-�" om\i9 . imps Ea IDE!Wa y United States Department of the Interior PRIDE M wca" BUREAU OF LAND MANAGEMENTalmlailliiiiiillim. NMI IM ,pcn 3'Oh Newcastle Resource Area 1101 Washington Boulevard Newcastle,Wyoming 82701-2972 WYW88760 2800 March 18, 1993 . 4A . Kissack Water and Oil Service, Inc. Box 9 O Rozet, WY 82727 Gentlemen: O C9 Your request, dated March 15, 1993, to dispose of approximately 8,000 -10,000 gallons per day (5 days per week) of brine waste water from the ConAgra Red Meat Company, Greeley, Colorado is hereby approved. This material is not covered by the petroleum exemption to RCRA. This waste has been sampled and found to be non-hazardous in character. This approval is for a one-year period only, and will be considered for extension after re-analysis of the waste. Any additional material generated at this site in the future will have to be analyzed separately. Sincerely, J4L F c E. Ewing Ar a Manager IIIVVV/// .... • ATTACHMENT "R" 9AIo7Q Post Office Box "G•" • r,,,,,, Greeley, Colorado 80632-0350 Phone: (303) 353-2311 Aim Red Meat Companies Bob Lucht, Supervisor Underground Injection Program Water Quality Division , Department of Environmental Quality State of Wyoming 122 W 25th St.. . Cheyenne, Wyoming 82002 Dear Sir; I am submitting a copy o4Ac aboratory analysis of the brine waste that is produced thro g e hide process at the Greeley Beef plant . We request .author# n to dispose of this liquid waste at the Injection Disposal Well operated by Eissack Water and Oil Service, Inca Rozet, Wyoming. The waste is primarily a saturated brine solution wasted from the hide curing operation. There are no heavy metals, petroleum hydrocarbons , or exotic hydrocarbons associated with the process in any way. The waste is passed through a 100 micron filter to remove as much organic material, fats, oil, grease, hair, and manure as possible. The resulting waste has a high level of Sodium-chloride and suspended solids . The ' suspended solids are manure and dirt particles that pass through the 100 micron filter. • i•f you need further information please do not hesitate to contact me at 303-353-2311 ext . 8233 . Thank you for your help in this • matter. Siincerly, n enOA Wes Potter, V. P. Environmental Operations Feeding People Better — 9410'79 ATTACHMENT "R" WRIGHT'S DISPOSAL 2323 South Wadsworth Blvd. ,Suite 107,Denver Co 80227 U.S.A. Telephone: 303 988-4500 Fax : 303 988-7962 Facsimile Transmittal, Sheet Transmitted to telephone No: 303 293.1234 Deliver. to: John Carson Location: EPA, Denver Pages Including Cover: 01 Date : July 26, 1993 • Dear John: As per our telephone conversation of today I understand that the Monfond (Con Agra ed R Meat) brine water has been approved by the EPA for disposal at our facility in Fort Lupton.. In enter to confirm the conversation , please sign in the space below. Thank you Sincerely M'Fae Martin J. Wohniicb Approved: Date: ,1993 By: (To'a ,n ATTACHMENT "C" 941079 w. I `"�. UNITED STATES ENVIRO NMENTAL PROTECTION AGENCY c� REGION VIII 999 18th STREET - SUITE 500 47 DENVER, COLORADO 80202-2466 SEP 31993 Ref: 8WM-DW CERTIFIED MAIL RETURN RECEIPT REOUESTED Martin J. Wohnlich Wright' s Disposal, Inc. 2323 South Wadsworth, Suite 107 Denver, Colorado 80227 RE: UNDERGROUND INJECTION CONTROL (UIC) Authorization to Inject Suckla Farms No.1 Well Class I Permit CO1516- 02115 Weld County, Colorado Dear Mr. Wohnlich: Thank you for the recently submitted test data pertaining to the above-referenced injection well . This information included the results of a mechanical integrity test, temperature log, radioactive tracer survey, and step-rate test. These tests were witnessed by a representative of the Environmental Protection Agency (EPA) and have been evaluated and approved. Therefore, Wright' s has complied with all pertinent permit 1 conditions [Part II, Sections A. 5 and C. 1 . ) and may begin operation as a Class I nonhazardous industrial waste injection well. To date, the only Class I fluid proposed for injection is a hide tanning waste brine from the ConAgra Red Meat Company in Greeley, Colorado. The laboratory analysis submitted for this fluid has been evaluated by EPA and determined to be non- hazardous in nature, and therefore, is approved for injection. For your guidance regarding additional fluid analyses of this fluid, as well as, any new source of Class I waste fluid, you are referred to Part II, Section C. 6 . and Section D. 1 . of the permit . Specifically, the permit requires that analyses shall include determinations of BTEX (benzene, toluene, ethylbenzene, xylene) , characteristics of corrosivity, ignitability, and reactivity, plus toxicity using the toxicity characteristic leachate procedure (TCLP) . All analyses must be submitted to EPA for evaluation prior to obtaining approval for delivery to the injection plant facility. Analysis of commingled Class I and Class II fluids prior to injection is to be performed at random, but not less than once every three months , for total dissolved solids , pH, specific conductivity, specific gravity, major cations and anions, oil and grease, and total organic carbon. ATTACHMENT "I)" 9410 74 • Martin J. Wohnlich ' Wright' s Disposal, Inc. a '' CO1516-02115 Page 2 � You are also required, under Part III, Section E. 6 . r , permit, to submit within sixty (60) days the names of three capable of performing an environmental audit of the plant an ' injection well surface facilities. EPA will then select one f ' - to conduct an audit twice each year, with the audit report sent to this office for evaluation. The purpose of the audits it- to evaluate the adequacy of facility operations and maintenance in preventing groundwater contamination. You are reminded that the maximum surface injection pressure for the well is currently 2 , 397 pounds per square inch gauge (psig) . If necessary, an adjustment to this pressure .-im. . may be made at a later date, based on the results of the afore - mentioned step-rate test of the Lyons injection zone . If you have any questions concerning this letter you may contact John Carson at (303 ) 293 - 1435 . Also. please direct all '.,; . correspondence to the attention of John Carson at Mail Code ! ';;, 8WM-DW. Thank you for your continued cooperation. NSincerely, / IN . Do n, Director Wafter Management Division cc: Frank J. Suckla ( Suckla Farms, Inc. Eugene S . Reynolds Mayor, City of Fort Lupton )111 Dennis Bicknell Colorado Oil & Gas Conservation Commission John S . Pickle Envi ronmental Protection Services Division Weld County Keith A. Schuett Department of Planning Services Weld County Ken Mersfelder Wright' s Disposal , Inc. 9410',9 aMonfort LABORATORY REPORT Monfort, Inc. Analytical Laboratory Attn: ED LEE, P.O. BoxG GREELEY PACK SEWAGE 650"0" Street Greeley, Colorado 80632 Work Order No. 910232 HIDE PLANT BRINE (303) 351-6344 Receive Date: 01 /14/91 Reported : 01 /23/91 Page: 1 Sample Date: 1-11-91 SNP,OATE IDENTIFICATION TYPE I.D. 01/11/91 HIDE PLANT BRINE BRINE 116224 pH 1.11 OIL/GREASE 60 PPN TOTAL DISSOLVED SOLIDS 320,000 PPN BOO 6600 PPM Michael Aaronson, PhD Laboratory Director 9410'79 15414 \II/ � OFFICE OF COUNTY ATTORNEY PHONE(303)356-4000 EXT.4391 !`\ P.O. BOX 1948 ig GREELEY,COLORADO 80632 Cs COLORADO March 2, 1994 VIA FACSIMILE TO 356-1111 Ken Lind, Esq. 1011 11th Avenue Greeley, CO 80631 RE: Disposal of Hide Brine Waste Water at Wright' s Disposal Dear Mr. Lind: The Board of County Commissioners has reviewed your recent letters concerning interim authority to accept hide brine waste water produced from the Con Agra Greeley plant pending a resolution of the Certificate of Designation Use by Special Review Application of Wright ' s Disposal . The Board has declined to grant such interim authority at this time given the delay in application for the Certificate of Designation and USR and in light of concerns which will be better addressed during the permit process, including the ongoing road impacts . Thank you for your cooperation in this matter. Very truly yours, WWee Morrison C � � Assistant Weld County Attorney LDM/gb: klind pc Board of County Commissioners Planning Department V t+ Weld County Health Department r1 Y Wes Potter, Con Agra Red Meats FAX - 3 is e:1 +' R 3 MAR 7 Plan .p��Aer, �� nia9 EXMISIT 9x10'79 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LAW BUILDING 1011 ELEVENTH AVENUE P.O. BOX 326 GREELEY, COLORADO 80632 GEORGE H. OTTENHOFF April 5, 1994 TELEPHONE KENNETH F. LIND (303) 353-2323 KIM R. LAWRENCE (303) 356-9160 TELECOPIER JEFFREY R. BURNS (303) 356-1111 Weld County Department of Planning Services 1400 North 17th Avenue Greeley, CO 80631 Attention: Keith Schuett Re : Wrights Disposal, Inc . (USR Application) Dear Mr. Schuett : On or about March 30, 1994 , Wrights Disposal was informed by the Colorado Department of Health that the public comment period would commence April 5, 1994 and be closed on May 5, 1994 . At the conclusion of the public comment, the State Department of Health will forward to Weld County their recommendation upon the Certificate of Designation. The comment letter should be received not later than May 10, 1994 . As this application has been on file since December of 1993 , and in light of the fact that the State Health Department is prepared to issue its recommendation upon the Certificate of Designation, we would request that the public hearing before the Planning Commission be scheduled for hearing on May 17, 1994 . We would request that you review the Planning Commission agenda for May 17, 1994 and determine if the USR hearing can be scheduled at that time . Due to the extensive review by the United States Environmental Protection Agency, we do not contemplate a lengthy hearing. At this time we would estimate that the applicant' s presentation will not exceed one hour in length. Should you have any questions regarding this request, please feel free to contact the undersigned. As to any questions regarding the time table by the State Department of Health, you can contact Steve Laudeman in Denver at 1-303-692-3462 . Mr. Laudeman is aware of the State public comment period and can confirm the information in this letter. Very truly ou LIND, N OTTENHOFF Kenn . Li d J �+IIr-VI -�V1LI�f ��/7-/7 C.. KFL/cg I`ll J Ir�T pc : Wrights Disposal, Inc . IfII EXHIBIT �5�1 APR 0 1991,L 941079 ft tilt6 • • DEPARTMENT OF PLANNING SERVICES PHONE (303)3533845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES 1111 I C. 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 COLORADO April 14, 1994 Ken Lind Lind, Lawrence, Ottenhoff 1011 Eleventh Avenue Greeley, Colorado 80631 Subject: USR-1039 - Wrights Disposal, Inc Dear Mr. Lind: Thank you for your April 5 letter. As stated in my December 17, 1993, letter the Planning Commission meeting date will be scheduled when the referral response is returned from the State Health Department. Scheduling the case prior would not allow sufficient time for the referral response to be included in the land use summary and to be given proper consideration for developing staff comments. Please call or write me if you have any questions. Sincerely, /X . Schuett Current Planner II pc: Chuck Cunliffe, USR-1039 4 EXHiilt I r .cd .,,, tL„, DEPARTMENT OF PLANNING SERVICES PHONE (303) 353-3845, EXT. 3540 ' WELD COUNTY ADMINISTRATIVE OFFiCES s : x +`� 1400 N. 17TH AVENUE f ` " GREELEY, COLORADO 80631 COLORADO December 17 , 1993 Ken Lind Lind, Lawrence, and Dttenhoff 1011 Eleventh Avenue Greeley, CO 80631 Subject: USR-1039 - Request for a Site Specific Development Plan, a Special Review permit, and a Certificate of Designation on a parcel of land approximately 40 acres described as 39 acres being in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, T1N, R67W of the 6th P.M. , Weld County, Colorado. Dear Mr. Lind: Your application for Wright' s Disposal, Inc. , and related materials for the request described above are being processed. I will schedule a meeting with the Weld County Planning Commission when the referral response is returned from the State Health Department. This meeting will take place in the County Commissioners' Hearing Room, first floor, Weld County Centennial Center, 915 10th Street, Greeley, Colorado. It is recommended that you and/or a representative be in attendance to answer any questions the Planning Commission members might have with respect to your application. It is the policy of Weld County to refer an application of this nature to any town or municipality lying within three miles of the property in question or if the property under consideration is located within the comprehensive planning area of a town or municipality. Therefore, our office has forwarded a copy of the submitted materials to the City of Ft. Lupton, the Town of Dacono, and the Tri-Area Planning Commissions for their review and comments . Please call Don Stephens, in Ft. Lupton, at 356-9225 , Nancy Elliott, in Dacono, at 833-2317, and Jay Curtis , Tri-Area, at 833- 3819, for further details regarding the date, time, and place of these meetings. It is recommended that you and/or a representative be in attendance at the Ft. Lupton, Dacono and Tri-Area Planning Commission Meetings to answer any questions the Commission members may have with respect to your application. It is the responsibility of an applicant to see that a sign is posted on the property under consideration at least 10 days preceding the hearing date. You will be notified of the sign posting requirements once the hearing date has been determined. 9410' 9 Wright's Disposal, Inc. December 17 , 1993 Page 2 The Department of Planning Services' staff will make a recommendation concerning this application to the Weld County Planning Commission. This recommendation will be available twenty-four (24) hours before the scheduled hearing. It is the responsibility of the applicant to call the Department of Planning Services' office before the Planning Commission hearing to make arrangements to obtain the recommendation. If you have any questions concerning this matter, please feel free to call me. Respectfully, Ifeit A.` c e Current Planner KAS/sfr 9,1.079 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH -owcoo Dedicated to protecting and improving the health and 4.-*" „-,r, environment of the people of Colorado ,�11 . t GPI "b' 4300 Cherry Creek Dr.5. Laboratory Building u Cn 4, • Denver,Colorado 80222-1530 4210 E.11th Avenue I —J �•(606 r Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 1 MAY 2 4 1994 Roy Romer Governor May 19, 1994 'r,"4 Fa,*' Patricia A.Nolan,MD,MPH r planning Executive Director Mr. Kenneth F. Lind Lind, Lawrence, and Ottenhoff P. O. Box 326 Greeley, Colorado 80632 RE: Certificate of Designation Application Technical Review Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Mr. Lind: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its technical review of Wright's Disposal, Inc.'s application for a Certificate of Designation, dated December 2, 1993 (referred to as "the Application"). This application to operate a liquid waste underground injection well was received in our offices on December 27, 1993. The Division's review was carried out as part of the Certificate of Designation application process to determine the proposed facility's compliance with the solid waste statute, C.R.S. 30-20-100.5, et seq., and with the regulations promulgated thereunder (6 CCR 1007-2) (the Regulations). As part of the technical review, it was necessary to determine which specific sections of the Regulations will apply to the proposed facility. The applicable requirements of Section 1 Administrative Information, Section 2 Minimum Standards, and Section 9 Waste Impoundments were used as a basis for the technical review. Sections 1 and 2 contain requirements for all solid waste disposal sites and facilities, while Section 9 contains requirements specific to liquid waste impoundments. The definition of "waste impoundment"from the Regulations includes excavations used for liquid waste disposal, and it is the Division's determination that the well used for disposal at the proposed facility falls under this definition. Furthermore, the dual use of the facility for disposal of Class II oil field wastes and Class I industrial and commercial wastes has complicated the Division's review. The review summarized in this letter was carried out with regard to Class I wastes only. The responsibility for regulating Class II wastes remains with the Colorado Oil and Gas Conservation Commission. Also, the Application contains statements to the effect that the Class I non-hazardous liquid wastes to be disposed of are not solid waste. The definition of solid waste found in CRS 30-20-101 (6) includes any liquid waste from commercial or industrial operations, such as the Class I wastes described in the Application. + EXHIBIT f A: Mr. Kenneth F. Lind May 19, 1994 Page 2 Based on the results of the technical review, there are several aspects of the Application that require additional information or clarification. The Division's comments regarding these are as follows: 1. It will be necessary to provide a description of the measures to be taken to characterize and dispose of all secondary wastes generated as part of the disposal of Class I wastes. These secondary wastes will include used filters and material accumulated on those filters, waste oil skimmed from the liquids, sediment from holding tanks, and any other wastes which will not be injected. Specific minimum information required includes the projected amounts of each of these wastes, the process that generated the waste, and verification that a hazardous waste determination will be performed. 2. To avoid improper or illegal disposal, it will be necessary to disallow access to the facility during periods when the facility is closed. 3. It may be necessary for this facility to file an Air Pollution Emission Notification with the Air Pollution Control Division of the Colorado Department of Health. The necessity of filing with APCD may be determined by contacting their offices at (303) 692-3150. 4. As of April 9, 1995, all solid waste disposal facilities in Colorado must have financial assurance in place to cover closure of the facility by an independent third party. As presented in the Application, there is currently financial assurance in place to cover the plugging and abandonment of the well. It will be necessary to implement further financial assurance to cover all additional closure requirements. This closure must include removal and disposal of all accumulated wastes, removal of all structures, and regrading of the property to return it to farmable condition. As required by Section 1.8 of the Regulations, an estimate of the highest possible cost of closure must be maintained by the facility at all times. 5. To verify that no wastes will be entering the uppermost aquifer and potentially impacting ground water, it will be necessary to furnish design and construction documents that verify the integrity and capacity of spill and overflow containment structures. Of specific concern are the gravel filled containment structures around the holding tanks and the sand filled sump adjacent to the truck unloading area. Additionally, it will be necessary to provide construction details for the french drain installed on the north and west sides of the facility and any and all secondary containment structures. It is not clear where the discharge point for the french drain is located and how any fluids collected will be disposed of. If the information provided in response to this comment is not sufficient, it may be necessary to implement ground water monitoring. 6. In the Certificate of Designation Documentation and Submittals portion of the Application, on page 19, paragraph one, it states that a "...discussion as 9410'7+1 Mr. Kenneth F. Lind May 19, 1994 Page 3 to the injection procedure for Class I water will follow...'. It is not clear from reading further in that section of the Application if that specific information is included. Please clarify this point. 7. The closure requirements of Section 9.10 of the Regulations, including characterization and disposal of any residual wastes and notification of the Division, must be addressed at the time of closure. 8. When this facility begins accepting Class I wastes for disposal, it will be subject to payment and reporting under the Hazardous Substance Response Fund (HSRF), as well as payment of the annual facility registration fee. Payment into the HSRF is volume dependent and are due on a quarterly basis. The annual registration fee is facility class and waste volume dependent, and is due on January 1 of each year. These comments must be addressed in a comprehensive written response prior to the Division completing its technical review of this application. Submittal of the requested information and responses to the Division's concerns may bring up other concerns, and as such further information may be requested. The Division is required to bill for its review of technical submittals,pursuant to CRS 30-20- 109 (2) (b). The current hourly rate is $72.47. It is anticipated that the total time required for the Division's review of the submittals on this site should not exceed twenty hours. I hope this letter clearly states the Division's position on this Application. If you have any questions or need any further clarification, please call me at (303) 692-3462. Sincerely, I Stephen Lau eman Geological Engineer Solid Waste Section Hazardous Materials and Waste Management Division cc: Martin Wohnlich, Wright's Disposal, Inc. Trevor Jiricek, Weld County Department of Health Keith Schuett, Weld County Department of Planning Services John Carson, United States Environmental Protection Agency Patricia Beaver, Colorado Oil and Gas Conservation Commission File: SW/WLD/WRI/2 941079 GABLEHOUSE, EPEL & LETSON A LAW'PARTNERSHIP Of PROFESSIONAL CORPORATIONS 1050 SEVENTEENTH STREET (3031572-0050 SUITE 1730 FAX(303)572-3037 DENVER,COLORADO 80265 June 23, 1994 Keith Schuette Weld County Planning Department 1400 North 17th Avenue Greeley, CO 80631 Re: Wright's Disposal's Application for a Special Use Permit for Suckla Farms Injection Well #1 Dear Mr. Schuette: This law firm represents Frank and Edith Suckla. The Sucklas live next to the injection well that is the subject of the application currently pending before your department. They also own the farmland surrounding the injection well and share the driveway with Wright's Disposal. Enclosed for your information is a copy of a letter sent to Wright's Disposal that transmits several concerns that the Sucklas have with the proposed installation of a gate at the end of the driveway where it meets County Road 19. The Sucklas request that the county take these concerns into account during the application review process. Please call me with any questions you might have. Sincerely, GABLEHOUSE, EPEL & TSON /o �A,A v a Thomas KMT/kt \rTiTAllenclosure 2 4 1994 cc Frank and Edith Suckla Dean and Carolyn Faulkner wrowel£nunt!plwnning Ken Lind EXHIBIT CYCLED PAPER ¢ 1 94107'3 GABLEHOUSE, EPEL & LETSON A LAW PARTNERSHIP OF PROFESSIONAL CORP(}AIP,A 1050 SEVENTEENTH STREET 1303)5730050 SUITE 1730 FAX(303)572-3037 DENVER,COLORADO 80265 Via Fax and Mail June 23, 1994 Martin J. Wohnlich Wright's Disposal 2323 S. Wadsworth, Suite 103 Denver, CO 80227 Re: Installation of Gate Across Driveway Dear Martin: Per our conversation, I am writing to summarize the concerns that Frank and Edith Suckla have expressed about the proposed installation of a gate across the driveway at the point where it meets County Road 19. As you know, the Sucklas will continue to use the driveway under easement rights after the property is sold. As a result, the Sucklas ask that Wright's Disposal inform Weld County of their concerns so that they may be duly considered by the permitting authorities. The Sucklas would prefer that no fence be installed anywhere across the driveway for several reasons. First, gate is not needed to'secure or restrict access to the injection well site. The injection well has been used for several years now to inject oil and gas production waters. There have never been any security problems associated with this use. Moreover, the Sucklas do not believe that the proposed use would change the security needs of the site. The site is located well back from County Road 19. What little traffic travels along County Road 19 is limited to nearby property owners and delivery trucks to Wright's Disposal. The site is not noticeable to general traffic traveling along the nearest highway. In short, the site does not attract attention. A gate placed across the driveway would impose a significant burden on Mr. Suckla and his wife. They have been using the driveway as is (without a gate) for over twenty years now. They are retired elderly farmers. It is not easy for them to get in and out of their car. If a gate were installed, they would be forced to do this on a regular basis. In short, the use of a gate would be difficult, if not impossible, for Mr. Suckla and his wife. Mr. Suckla believes that a better location for a gate, if one must be built, would be closer to the injection facility as shown on the enclosed map. This location would enable the Sucklas to avoid having to go through the gate by using an existing alternative route that circumvents the facility. The alternative route is located on land that will remain owned by PRINTED ON RECYCLED PAPER 94107=3 Mr. Martin J. Wohnlich June 23, 1994 page 2 the Sucklas. Please note that the Sucklas are not suggesting the property be fenced. A fence would interfere with their ongoing farming activities on land adjacent to the driveway. Further, the Sucklas note that a gate located along Road 19 would not be feasible. A gate at such location will be knocked over by delivery trucks. Mailboxes located along Road 19 where it meets the driveway have been knocked over in the past on several occasions. Mr. Suckla is concerned that the addition of a gate in the same general vicinity as the mailboxes would further crowd the entranceway. Also, trucks would have to stop on Road 19 if the gate were closed. This would impede the traffic along the road. The Suckla Farms family has no objection to the issuance of a permit at this time. But because they will continue to be close neighbors of the injection well and will share the use of the driveway with Wright's Disposal, they are interested in ensuring compatible uses. They strongly urge that the state and county reconsider the need for a gate. At a minimum, they request that the location of the gate be moved as indicated on the map. Please call me with any questions or comments that you may have. Sincerely, ABLEHOUSE, EPEL & ON O Q > , Karina M. Thomas KMT/kt enclosure cc Frank and Edith Suckla Carolyn & Dean Faulkner Ken Lind Paul G. Bursiek 9410'79 SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 21 .94 15 :38 No .005 P .01 SIMLA CORPORATION 2323 South Wadsworth Blvd, Suite 107,Denver,CO 80227,USA Telephone: (303)988-4500,Fax: (303) 988-7962 FAX TRANSMITTAL SHEET Pages Including Cover: 2 From : Martin Wohnlich Deliver to : Keith Sehuett Date : July 21, 1994 At: Weld County Planning Time : 4:35 PM Transmit to Fax No : 303 351-0978 Re: Wright's Disposal Dear Keith: As discussed on the telephone today please find attached the Certificate of Designation Application approval from the Colorado Department of Health. I understand that you will now set a meeting with the Planning Commission. Please let me know what that date is and in the meantime please feel free to contact me for anything you might require. Sincerely AV,'"ade Martin J.Wohnlich d EXHIBIT JUL 21 '94 15:36 t'*a. .=LL. 7%2 PAGE.E4lo7s SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 21 ,94 15 :39 No .005 P .02 STATE OF COLORADO Roy Rant,Governor Preside A.Nolen,MD,MPH,Dacwre Motto t4 Mak:NW to preiredsrandMpmwlnjue,healtlimdenwronnewaachepeopleaeoandu 4300 Cheenrryy Creek or.a Laboratoty addlesDenver,Coloredoe0222-1530 4210E.1 et Avenue phone(303)69x-2000 �33003)sti'�0 06023Wr16 ColoradoDcputmcnt leakh July 21, 1994 ef nd�Publicf Weld County Board of County Commissioners County Commissioners Office 915 10th Street Greeley, Colorado 80632 RE: Certificate of Designation Application Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Commissioners; The Solid Waste Section of the Hazardous Materials and Waste Management Division(the Division) has completed its review of Wright's Disposal Inc.'s Certificate of Designation Application to operate a liquid waste disposal facility in Weld County. The Division hereby determines that,based on information submitted by the applicant and subsequent correspondence, and contingent the requirements stated in the Division's July 19, 1994 letter to Mr.Martin Wohnllch being adequately addressed,all requirements of the • Solid Wastes Disposal Sites and Facilities Act (CRS. 30-20-1 et cep.) have been met. A copy of the July 19, 1994 letter is enclosed. This determination serves as recommendation to the Weld County Board of County Commissioners that a Certificate of Designation for solid waste disposal as documented in the referenced Wright's Disposal submittals may be granted for this facility. I hope this letter have any questions regayrding this matter, please states the Division's s contact me at (303) 6923462.ition on the status of this f facility. If you Sinter a�Ste n demsa lerm F. Mallory Geo gi Engineer Section Chief Solid Waste Section Solid Waste Section Hazardous Materials Hazardous Materials and Waste Management Division and Waste Management Division enclosure cc: Martin Wohnlich,Wright's Disposal, Inc.w/o enclosure Kenneth Lind, Lind, Lawrence, and Ottenhoff w/o enclosure Keith Schlott, Weld County Planning Department w/ enclosure Trevor Jiricek, Weld County Department of Health w/o enclosure John Carson, US Environmental Protection Agency w/o enclosure Patricia Beaver, Colorado Oil and Gas Conservation Commission w/o enclosure File: SW/WLD/WRI/2 JUL 21 '94 1537 303 990 7962 PAGE.°9410'79 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LAW BUILDING 1011 ELEVENTH AVENUE P.O. BOX 326 GREELEY, COLORADO 80632 GEORGE H. OTTENHOFF TELEPHONE KENNETH F. LIND (303) 353-2323 KIM R. LAWRENCE July as , 1994 (303) 356-9160 y TELECOPIER JEFFREY IL BURNS (303) 356-1111 Weld County Department of Planning Services 1400 North 17th Avenue Greeley, CO 80631 Attention: Keith Schuett Re : Wrights Disposal, Inc . Dear Mr. Schuett : Enclosed is a copy of a letter dated July 19, 1994 from the Colorado Department of Public Health and Environment . Please notice in Paragraph 4 that they will be recommending approval of Wright' s Disposal' s Application fora Certification of Designation. Based upon this recommendation, would it be possible to schedule the Planning Commission hearing for the 3rd Tuesday in August? Please let me know. Thank you. Very truly yours, LIND, LA TENHOFF _` , Kenne F1.' Lind KFL/cg Enclosure pc : Wrights Disposal, Inc . Karina M. Thomas, Esq. \fit 0 �� ,lUl 2 1994 4 EXIII IT ' . 9411 STATE OF COLORADO Roy Romer,Governor of[O MPH,Executive Director � Patricia A.Nolan,MD, N< Dedicated to protecting and improving the health and environment of the people of Colorado * ' i 4300 Cherry Creek Dr.S. Laboratory Building • Denver,Colorado 80222-1530 4210 E.11th Avenue '1876` Phone(303)692-2000 Denver,303)691-4700 Colorado 80220-3716 ( Colorado Department of Public Health and Environment July 19, 1994 Mr. Martin Wohnlich Wright's Disposal, Inc. 2323 South Wadsworth Blvd., Suite 103 Denver, Colorado 80227 RE: Certificate of Designation Application Technical Review Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Mr. Wohnlich: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Hepworth-Pawlak Geotechnical, Inc.'s letter of July 18, 1993 regarding installation of ground water monitoring wells at the Wright's Disposal facility. These ground water monitoring wells were installed in response to concerns expressed in the Division's June 9, 1994 letter. Based on a review of the information provided, the Division finds that the three wells as installed (designated OW-1, OW-2, and OW-3) will serve to satisfy the Division's request for installation of a ground water monitoring system. As we have discussed, the last remaining concerns of the Division have to do with the parameter list for monitoring and the monitoring frequency. The Division requires that the minimum parameter list consist of the constituents listed in Appendix IA of the Solid Waste Regulations (6 CCR 1007-2) and benzene, ethyl benzene, toluene, and xylene, (BTEX) and Total Petroleum Hydrocarbons (TPH). All sampling and analyses must follow standard accepted protocols and utilize EPA approved methods. A copy of Appendix I of the Regulations is enclosed for your reference. The Division requires that individual samples be obtained from each well and analyzed on a semi-annual basis (twice per year). In addition to obtaining samples for analysis, it will be necessary to determine the elevation of water in each well at each sampling event and use this information to determine the direction of flow and the magnitude of the hydraulic gradient. All analytical results and other monitoring information must be submitted to the Division and Weld County Health Department after each sampling event. As all concerns of the Division regarding the Certificate of Designation Application for this facility have now been met, a letter will be sent to the Weld County Planning Department recommmending approval of Wright's Disposal's Application for a Certificate of Designation. I hope this letter clearly states the Division's position on the status of this facility. If you have }' 941678 Mr. Martin Wohnlich July 19, 1994 Page 2 any questions regarding this matter, please contact me at (303) 692-3462. Sincerely, Stephe Lau an Geolog al Engineer Solid Waste Section Hazardous Materials and Waste Management Division enclosure cc: Kenneth Lind, Lind, Lawrence, and Ottenhoff Trevor Jiricek, Weld County Department of Health w/copy of July 18, 1994 letter John Carson, US Environmental Protection Agency w/copy of July 18, 1994 letter Patricia Beaver, Colorado Oil and Gas Conservation Commission File: SW/WLD/WRI/2 • • 942078 SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 25 ,94 9 :44 No .003 P .01 SIMLA CORPORATION 2323 South Wadsworth Blvd,Suite 107,Denver,CO 80227,USA Telephone : (303)988-4500,Fax: (303)988-7962 FAX TRANSMITTAL SHEET Pages including Covor: 6 From : Martin Wohnlich Deliver to : Keith Schnell Date : July 25, 1994 At: Weld County Planning Time : 10:21 AM Transmit to Fax No : 303 351-0978 Re: Wright's Disposal Dear Keith: As discussed on the telephone today please find attached the July 19, 1994 letter from the Colorado Department of Health together with the Appendix I, We have taken note that the meeting with the planning commission has been set for September 8, 1994. Please be sure to let me know if you require any further information. Sincerely ivcd7a--e Martin J. Wohnlich • J � V tJUL 2 1994 . -. Ol. nMflP • $XHI$IT JUL 25 '94 09:42 303 988 7962 P1941A8. SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 25 ,94 9 :44 No .003 P .02 OF COLORADO STATE ...Roy Romer,Governor p:. Petrlcla A.Nolan,MD,MPH,Executive Director _yr Dedicated to protecting and improving the health and environment of the people of Cokrado ...- -t 4300 Cherry Creek Dr.S. Laboratory Building Denver,Colorado 80222.1530 42101.11th Avenue 'I LZ Phone(303)692-20(X1 Denver,Colorado 80220-3716 (303)691-17(10 Colorado�ent of July 19, 1994 and iemn nt Mr. Martin Wohnlich Wright's Disposal, Inc. 2323 South Wadsworth Blvd., Suite 103 Denver, Colorado 80227 RE: Certificate of Designation Application Technical Review _. -" Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Mr. Wolmlich: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Hepworth-Pawlak Geotechnical, Inc.'s letter of July 18, 1993 regarding installation of ground water monitoring wells at the Wright's Disposal facility. These ground water monitoring wells were installed in response to concerns expressed in the Division's June 9, 1994 letter. . Based on a review of the information provided,the Division fmds that the three wells as installed (designated OW-I, OW-2, and OW-3)will serve to satisfy the Division's request for installation of a ground water monitoring system. As we have discussed, the last remaining concerns of the Division have to do with the parameter list for monitoring and the monitoring frequency. The Division requires that the minimum parameter list consist of the constituents listed in Appendix IA of the Solid Waste Regulations (6 CCR 1007-2) and benzene, ethyl benzene, toluene, and xylene, (BTEX) and Total Petroleum Hydrocarbons (TPII). All sampling and analyses must follow standard accepted protocols and utilize EPA approved methods. A copy of Appendix I of the Regulations is enclosed for your reference, The Division requires that individual samples be obtained from each well and analyzed on a semi-annual basis (twice per year). In addition to obtaining samples for analysis, it will be necessary to determine the elevation.of water in each well at each sampling event and use this _information to determine the direction of flow and the magnitude of the hydraulic gradient. All analytical results and other monitoring information must be submitted to the Division and Weld County Health Department after each sampling event. As all concerns of the Division regarding the Certificate of Designation Application for this facility have now been met, a letter will be sent to the Weld County Planning Department recommmcnding approval of Wright's Disposal's Application for a Certificate of Designation. I hope this letter clearly states the Division's position on the status of this facility. If you have r,ww .a) JUL 25 '94 09 43 303 988 7962 PAGE X02 1341078 SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 25 ,94 9 :44 No .003 P .03 Mr. Martin Wohnlich July 19, 1994 Page 2 any questions regarding this matter, please contact me at (303) 692-3462. Sincerely, Stepheau an Geolog Engineer Solid Waste Section Hazardous Materials and Waste Management Division cc: Kenneth Lind, Lind, Lawrence, and Ottenhoff Trevor Jiricek, Weld County Department of Ikalth w/copy of July 18, 1994 letter John Carson, US Environmental Protection Agency w/copy of July 18, 1994 letter Patricia Beaver, Colorado Oil and Gas Conservation Commission File: SW/WLD/WRI/2 JUL 25 '94 09:43 303 988 7962 PRGE.003 941078 SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 25 .94 9 :46 No .003 P .04 • JIPPENDIY I FOR DETECTION JLONITORING APPENDIX IA GENERAL GROUND WATER QUALITY INDICATOR PARAMETERS CATION$ MAGNESIUM SODIUM POTASSIUM CALCIUM ARUM CARBONATE BICARBONATE CHLORIDE SULFATE NITRITE NITRATE FIELD PARAMETERS PR SPECIFIC CONDUCTIVITY TEMPERATURE TOTAL ORGANIC CARBON APPENDIX IB COMMON NAME CAS NUMBER INORGANIC CONSTITUENTS (1) ANTIMONY(TOTAL) (2) ARSENIC(TOTAL) (3) BARIUM(TOTAL) (4) BERYLLIUM(TOTAL) (5) CADMIUM(TOTAL) (6) CHROMIUM (TOTAL) (7) COBALT (TOTAL) (8) COPPER (TOTAL) (9) LEAD (TOTAL) (10) NICKEL. (TOTAL) (11) SELENIUM (TOTAL) (12) SILVER (TOTAL) (13) THALLIUM (TOTAL) (14) VANADIUM (TOTAL) (15) ZINC (TOTAL) ORGANIC CONSTITUENTS: (16) ACETONE 67-64-1 (17) ACRYLONITRILE 107-13-1 (18) BENZENE 71-43-2 (19) BROMOCHLOROMETHANE 74-97-5 (20) BROMODICHLOROMETHANE 75-27-4 JANUARY 30, 1994 139 JUL 25 '94 09:44 303 968 7962 PAGEb4 941078 SIMLR CORP . DENVER USR TEL :303-988-7962 Jul 25 .94 9 :46 No .003 P .05 (21) BROMOFORM; TRIBROMOMETHANE 75-25-2 (22) CARBON DISULFIDE 75-15-0 (23) CARBON TETRACHLORIDE 56-23-5 (24) CHLOROBENZENE 1Q8-9p-7 (25) CHLOROETHANE; ETHYL CHLORIDE 75-00-3 (26) CHLOROFORM; TRICHLOROMETHANE 67-66-3 (27) DIBROMOCHLOROMETHANE; CHLORODIBROMONETHANE 124-48-1 (28) 1,2-DIBROMO-3-CHLOROPROPANE; DBCP 96-12-8 (29) 1,2-DIBROMOETHANE; ETHYLENE DIBROMIDE; EDB 106-93-4 (30) O-DICHLOROBENZENE; 1,2-DICHLOROBENZENE 95-50-1 (31) P-DICHLOROBENZENE; 1,4-DICHLOROBENZENE 106-46-7 (32) TRANS-1,4-DICHLORO-2-BUTENE 110=57-6 (33) 1,1-DICHLOROETHANE; ETHYLIDENE CHLORIDE 75-34-3 (34) 1,2-DICHLOROETHANE; ETHYLENE DICHLORIDEI07-06-2 (35) 1,1-DICHLOR0ETHYLENE; 1,1-DICHLOROETHENE; VINYLIDEN CHLORIDE 75-35-4 (36) CIS-1,2-DICHLOROETHYLENE; CIS-1,2-DICHLOROETHENE 156-59-2 ( 3 7 ) TRANS - 1 , 2 - D I C H L O R O E T H Y L E N E ; TRANS-I,2-DICHLOROETHENE 156-60-5, (38) 1,2-DICHLOROPROPANE; PROPYLENE DICHLORIDE 78-87-5 (39) CIS-1,3-DICHLOROPROPENE 10061-01-5 (40) TRANS-1,3-DICHLOROPROPENE • ( 10061-02-6 (41) ETHYLBENZENE 100-41-4 (42) 2-HEXANONE; METHYL BUTYL KETONE 591-78-6 (43) METHYL BROMIDE; BROMOMETHANE 74-83-9 (44) METHYL CHLORIDE; CHLOR0METHANE 74-87-3 (45) METHYLENE BROMIDE; DIBROMOMETHANE 74-95-3 (46) METHYLENE CHLORIDE; DICHLOROMETHANE 75-09-2 (47) METHYL ETHYL KETONE; MEK; 2-BUTANONE 78-93-3 (48) METHYL IODIDE; IODOMETHANE 74-88-4 (49) 4-METHYL-2-PENTANONE; METHYL ISOBUTYL KETONE 108-10-1 (50) STYRENE 100-42-5 (51) 1, 1,1,2-TETRACHLOROETHANE 630-20-6 (52) 1, 1,2,2-TETRACHLOROETHANE 79-34-5 ( 53 ) TETRACHLOROETHYLENE ; TETRACHLOROETHENE PERCHLOROETHYLENE 127-18-4 (54) TOLUENE 108-88-3 (55) 1, 1,1-TRICHLOROETHANE; METHYLCHLOROFORM 71-55-6 (56) 1,1,2-TRICHLOROETHANE 79-00-5 (57) TRICHLOROETHYLENE; TRICHLOROETHENE 79-01-6 (58) TRICHLOROFLUOROMETHANE; CFC-11 75-69-4 (59) 1,2,3-TRICHLOR0PR0PANE 96-18-4 (60) VINYL ACETATE . 108-05-4 (61) VINYL CHLORIDE 75-01-4 (62) XYLENES 1330-20-7 JANUARY 30, 1994 140 JUL 25 '94 09:44 303 988 7962 PAGE:815 941078 SIMLA CORP . DENVER USA TEL :303-988-7962 Jul 25 ,94 9 :46 No .003 P .06 This list contains 47 volatile organics for which possible analytical procedures provided in EPA report SW-846 "Test Methods for Evaluating Solid waste;" third edition, November 1986, as revised December 1987, includes method 8260; and 15 metals for which SW-846 provides either method 6010 or a method from the 7000 series of methods. Common names are those widely used in government regulations, scientific publications, and commerce; synonyms exist for many chemicals. Cas number mg Chemical Abstracts Service registry number. • JANUARY 30, 1994 141 JUL 25 '94 09:45 303 988 7962 PRGE_00f10 • . p DEPARTMENT OF PLANNING SERVICES PHONE (303) 353-3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES WI C. Y, N ORA O8NUE GREELEY, COLORADO80631 COLORADO August 2, 1994 Ken Lind Lind, Lawrence, and Ottenhof 1011 Eleventh Avenue Greeley, CO 80631 Subject: USR-1039 - Request for a Site Specific Development Plan, Special Review permit, and a Certificate of Designation on a parcel of land described as 39 acres being located in the S2 of the E2 of the NW4 and approximately 1 acre in the SW4 of Section 10, TIN, R67W of the 6th P.M. , Weld County, Colorado for an injection well for the disposal of Class I and II liquid waste as defined in the code of Federal Regulations (40 cfr 144.6) , in the A (Agricultural) zone district. Dear Mr. Lind: Your application and related materials for the request described above are being processed. I have scheduled a meeting with the Weld County Planning Commission for Thursday, September 8, 1994, at 1:30 p.m. This meeting will take place in the County Commissioners' Hearing Room, first floor, Weld County Centennial Center, 915 10th Street, Greeley, Colorado. It is recommended that you and/or a representative be in attendance to answer any questions the Planning Commission members might have with respect to your application. Sometime prior to August 26, 1994, a representative from the Department of Planning Services will be out to the property to post a sign adjacent to and visible from a publicly maintained road right-of-way which identifies the hearing time, date, and location. In the event the property under consideration is not adjacent to a publicly maintained road right-of-way, one sign will be posted in the most prominent place on the property and a second sign will be posted at the point at which the driveway (access drive) intersects a publicly maintained road right-of-way. The Department of Planning Services ' staff will make a recommendation concerning this application to the Weld County Planning Commission. This recommendation will be available twenty-four (24) hours before the scheduled hearing. It is the responsibility of the applicant to call the Department of Planning Services ' office before the Planning Commission hearing to make arrangements to obtain the recommendation. If you have any questions concerning this matter, please feel free to call me. Respectfully, PV" ° EXHIBIT 1[i 941078 I 1-1 T Tel: (303) 988.4500 WRIGHT'S DISPOSAL INC. Fax: (303) 988.7982 2323 S. Wadsworth, Suite 103, Denver, Colorado 80227 Mr. Keith Schuett Department of Planning Services Weld County Administrative Offices 1400 N. 17th Avenue Greeley, CO 80631 August 3, 1994 Re; Wright's Disposal Dear Keith: As requested at our meeting in your offices yesterday please find attached the EPA letter dated December 2, 1993 adjusting the maximum injection pressure to 3,700 psig. This pressure corresponds to an injection rate of 8 Bbls per minute or 11,520 Bbls per day. Our letter of September 10, 1993 is also attached. The MSDS sheets you requested on the chemicals currently in use at the plant are enclosed. Please note that we, as a matter of policy, keep this information on site and it is available to you at any time. I reviewed the automatic shut off question you had with our plant manager Ron Veik. The large 400 Bbl storage tanks do not have an automatic overflow shut off system. The reason for this is that we never take on water unless an operator is present. The operator visually checks the water level in the main tanks. MI the tanks are interconnected both on top and at the bottom. This visual control is one of the operators most important tasks. We have not had a tank overflow since we started operations five years ago. The 300 Bbl filter water tank is fully automatic. This means that it automatically shuts off the filter pumps if the water level gets too high and also shuts off the main injection pumps if the water level in the tank gets too low. I did meet with Drew Scheltinga to review the traffic questions and he will send you an updated memo after he has reviewed the information I sent him. I trust the above responds to your questions. Please feel free to call with any further questions you may have. Sincerely ei/SVAtieior c , Martin J. Wohnlich 'PUG 0 1994 "P"<�„",My Planning y ' I• EXHIBIT 941078 . UNITED STA. ES ENVIRONMENTAL PROTECTIvN AGENCY REGION VIII o 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 DEC 6I993 Ref: 8WM-DW CERTIFIED MAIL RETURN RECEIPT REOUESTED Martin J. Wohnlich Wright's Disposal, Inc. 2323 South Wadsworth, Suite 103 Denver, Colorado 80227 RE: UNDERGROUND INJECTION CONTROL (UIC) Minor Permit Modification for the Class I Suckla Farms #1 Well (EPA Permit #CO1516-02115) Weld County, Colorado Dear Mr. Wohnlich: Enclosed is a minor modification to the above-referenced permit. Your request to increase the maximum surface injection pressure Was received in our office on September 10, 1993 . The results of a step-rate test performed in the Suckla Farms #1 well support your request for an adjustment in injection pressure; therefore, your request has been approved. The enclosed "Addendum to Statement of Basis" discusses the reasons for the permit modification and the upward adjustment of injection pressure from 2, 397 pounds per square inch gauge (psig) to a maximum of 3, 700 psig. If you have any questions on this action, you may contact John Carson at (303) 293-1435. Also, please direct all correspondence to the attention of John Carson at Mail Code 8WM-DW. Sincerely, . Do n, Director Wa r Management Division Enclosures: Addendum to Statement of Basis Minor Permit Modification Printed on Recycled Paper .. 941078 s'`�°"'b, UNITED STATr- ENVIRONMENTAL PROTECTIO' \GENCY (\ram) REGION VIII 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 MINOR PERMIT MODIFICATION Class I Well Suckla Farms #1 EPA Permit #CO1516-02115 Pursuant to Part III, Section B. 1 . of the above-referenced Class I Underground Injection Control (UIC) permit, a modification to said permit is to be made. Changes to the original version of Part II, Section C. 4 . (a) are as follows : Original version:. 4 . Injection Pressure Limitation. (a) Injection pressure, measured at the surface, shall not exceed 2 , 397 pounds per square inch gauge. Is Modified to read: 4 . Injection Pressure Limitation. (a) Injection pressure, measured at the surface, shall not exceed 3 , 700 pounds per square inch gauge. All other provisions and conditions of the final permit for the Suckla Farms #1 well remain as originally issued. December 3, 1993 Date x . Dodso , Director Wat Management Division EPA Permit #CO1516-02115 Page 1 of 1 Printed on Recycled Paper 941078 Addendum to Statement of Basis for EPA Permit #CO1516-02115 Class I Well Suckla Farms #1 Date prepared 10/8/93 Wright' s Disposal, Inc. submitted a request for a minor permit modification on September 10, 1993 . The request was to increase the maximum permitted surface injection pressure from 2, 397 pounds per square inch gauge (psig) to 3 , 700 psig, based on the results of a step-rate test of the Lyons injection zone (9,276-9,418 feet) in the Suckla Farms #1 disposal well . Infection Pressure: A review of data from a step-rate test performed on July 9, 1993, indicates that no formation breakdown of the Lyons occurred up to the termination of the test at a surface injection of 3 , 700 psig at an injection rate of 8 . 0 barrels of water per minute. This surface injection pressure, adjusted for hydrostatic pressure and friction loss in the tubing string, corresponds to a bottom-hole pressure of 4, 515 psig. Subsequent to the step-rate test, a temperature log and a radioactive tracer survey were run in the well during injection. Both tests indicated that all fluids were entering and being contained in the injection zone. Under Part II, Section C. 4. of the permit, the injection pressure may be increased by the Director if the permittee demonstrates that the proposed increase in surface injection pressure will not exceed the injection formation fracture pressure. The pressure limit is to be determined by performing a step-rate test or other authorized well test (s) . Therefore, on the basis of the test results, a maximum surface injection pressure of 3, 700 psig shall be approved for the Suckla Farms #1. EPA Permit #CO1516-02115 Page 1 of 2 941078 Suckle Farms Injection Well #1 Wright's Disposal, Inc. - CO1516-02115 4000 3500 Figure 1 . a 3000 Step Rate Injection Test cc 2500 cn ccill 2000 1500 S J d 1000 500 0 0 1 2 3 4 5 6 7 8 RATE (bbl/min) EPA Permit #C01516-02115 Page 2 of 2 �._...._..__.. ....,.... 94107$_ _ Tel: (303) 988.4500 Fax: (303) 988.7962 RIGIEIT S DISPOSAL. .INC. 2323 S. Wadsworth, Suite 103, Denver, Colorado 80227 14 John Carson Mail Code'.8WM-DW United States Environmental Protection Agency 999 18th Street, Suite 500 Denver,Co 80202-2466 Re; Class I Permit No: Co1516-02115 September 10, 1993 Dear John: Thank you very much for your letter dated September 3, 1993 permitting us to start operations as a Class I nonhazardous industrial waste injection well. As you are aware the State of Colorado has taken the position that our plant needs to be approved under a Certificate of Designation (CD) before we can start operations in spite of the fact that the Colorado Oil and Gas Conservation Commission already approved operations in 1989. As part of the CD Weld County will also require a Special Use Permit. Both these permits will describe the well in terms of the injection pressure limits and injection volumes set by the EPA. We are now informed, that once these permits have been granted any change in the injection pressure or injection volumes will require a new complete re-permitting of the facility. In order to avoid this costly and time consuming operation we would like to request at this time that the above permit be amended as follows: Injection Pressure The step rate test conducted July 9, 1993 indicated that we had not reached frac gradient;at 8 barrels per minute with a pressure of 3,700 lbs. Therefore we would like for tltnew injection pressure limit to be set at 3,700 lbs. Injection Volume The current permit allows for a total injection volume of 8,300,000 barrels with the understanding that this limit may be changed once the limit is reached. In view of the state and county permit regulations we would like to request that the injection volume be changed to allow the fluid to fill a 1/2 mile radius since there are no Lyons 94107$ ' ) -2- formation wells in the area. This change would allow a maximum injection volume of 33,000,000 barrels. The volume increase could also be justified by assuming a higher formation porosity which is indicated by the test results, specifically the step rate test. Mr Andy Peterson of Peterson Energy Management Inc. supports these changes in his report to you dated August 28, 1993. Should you need any further information, please do no hesitate to call. Sincerely re/ly�AKPetee Martin J. Wohnlich • • 941078 MSDS: 002-93 TWIN-KEM INTERNATIONAL, INC. PAGE : 01 MATERIAL SAFETY DATA SHEET EFFECTIVE DATE: 06/10/93 WRIGHT' S DISPOSAL, INC. 13050 WELD COUNTY ROAD #16 FT. LUPTON, CO 80621 PHONE (303) 857-0655 ****************** EMERGENCY ASSISTANCE ****************** FOR EMERGENCY ASSISTANCE INVOLVING CHEMICALS CALL: CHEMTREC (800-424-9300) PRODUCT AND SALES INFORMATION TWIN-KEM INTERNATIONAL, INC. 4220 S . ALLISON STREET, LAKEWOOD PHONE ( 303 ) 986-6440 FAX ( 303 ) 988-8202 PRODUCT IDENTIFICATION PRODUCT NAME: SCALE-NIX 160 CAS NO. : 7320-34-5 COMMON NAMES SYNONYMS: MIXTURE VARIOUS PHOSPHATES - SOLUTION VARIOUS CHELATING SALTS - SOLUTION FORMULA: MIXTURE HAZARD RATING (NFPA 704 CRITERIA) HEALTH: 0/1 HAZARD RATING SCALE : FIRE: 0 0=MINIMAL 3=SEVERE REACTIVITY: 0 1=SLIGHT 4=SERIOUS SPECIAL: NONE 2=MODERATE HAZARDOUS INGREDIENTS EXPOSURE LIMITS : PPM OSHA ACGIH OTHER COMPONENT CAS NO: $ PEL TLV LIMIT HAZARD PHOSPHATES 320-34-5 56 NONE NONE NONE NONE CHELATING AGENTS MIXTURE 7 NONE NONE NONE NONE WATER 7732-18-5 37 PHYSICAL PROPERTIES BOILING POINT: DEG F: >230 VAPOR PRESSURE : MM HG/20 DEG C :N/D MELTING POINT: DEG F: -58 VAPOR DENSITY (AIR=1 ) : N/D 941078 MSDS NO: 002-93 TWIN-KEM INTERNATIONAL, INC. PAGE : 02 MATERIAL SAFETY DATA SHEET PRODUCT: SCALE-NIX 160 SPECIFIC GRAVITY (WATER-1 ) : 1 . 74 . WATER SOLUBILITY: % : SOLUBLE APPEARANCE AND ODOR: EVAPORATION RATE (BUTYL ACETATE=1 ) N/D NO ODOR - SLIGHTLY CLEAR VISCOUS LIQUID - SLIGHTLY AMBER FIRST AID MEASURES IF INHALED: REMOVE TO FRESH AIR. GIVE ARTIFICIAL RESPIRATION IF NOT BREATHING. GET IMMEDIATE MEDICAL ATTENTION. IN CASE OF EYE CONTACT: IMMEDIATELY FLUSH WITH LOTS OF RUNNING WATER FOR 15 MINUTES, LIFTING THE UPPER AND LOWER EYELIDS OCCASIONALLY. GET IMMEDIATE MEDICAL ATTENTION. IF SWALLOWED: DO NOT INDUCE VOMITING. GET IMMEDIATE MEDICAL ATTENTION. HEALTH HAZARD INFORMATION PRIMARY ROUTES OF EXPOSURE : SKIN OR EYE CONTACT SIGNS AND SYMPTOMS OF EXPOSURE : INHALATION: BREATHING MIST MAY IRRITATE THE NOSE AND THROAT AND CAUSE COUGHING AND CHEST DISCOMFORT. EYE CONTACT: DUSTS MAY IRRITATE THE EYES SKIN CONTACT: NO IRRITATION IS LIKELY AFTER BRIEF CONTACT BUT MAY BE IRRITATING AFTER PROLONGED CONTACT. SWALLOWED: SWALLOWED LARGE QUANTITIES MAY CAUSE NAUSEA AND VOMITING. CHRONIC EFFECTS OF EXPOSURE: NO SPECIFIC INFORMATION AVAILABLE . MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE : NONE REPORTED. TOXICITY DATA ORAL: ANHYDROUS : RAT LD50 = 2980 MG/KG DERMAL: ANHYDROUS: RABBIT LD50 > 7940 MG/KG INHALATION: NO DATA FOUND 941078 MSDS : 003-93 TWIN-KEM INTERNATIONAL, INC. PAGE : 03 MATERIAL SAFETY DATA SHEET PRODUCT: SCALE-NIX 160 CARCINOGENICITY: THIS MATERIAL IS NOT CONSIDERED TO BE A CARCINOGEN BY THE NATIONAL TOXICITY PROGRAM, THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER, OR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION. OTHER DATA: NONE. PERSONAL PROTECTION VENTILATION: GENERAL ROOM VENTILATION. RESPIRATORY PROTECTION: A RESPIRATOR IS NORMALLY NOT REQUIRED IF THIS PRODUCT IS USED WITH ADEQUATE VENTILATION. EYE PROTECTION: CHEMICAL GOGGLES . IT IS GENERALLY RECOGNIZED THAT CONTACT LENSES SHOULD NOT BE WORN WHEN WORKING WITH CHEMICALS BECAUSE CONTACT LENSES MAY CONTRIBUTE TO THE SEVERITY OF AN EYE INJURY. PROTECTIVE CLOTHING: LONG SLEEVED SHIRT, TROUSERS, SAFETY SHOES AND GLOVES. OTHER PROTECTIVE MEASURES : AN EYEWASH AND SAFETY SHOWER SHOULD BE NEARBY AND READY FOR USE . FIRE AND EXPLOSION INFORMATION FLASH POINT: DEG F: NON-COMBUSTIBLE . METHOD USED: N/A FLAMMABLE LIMITS IN AIR: % LOWER: N/A. UPPER: N/A EXTINGUISHING MEDIA: THIS MATERIAL IS NOT COMBUSTIBLE . USE EXTINGUISHING MEDIAS APPROPRIATE FOR SURROUNDING FIRE . SPECIAL FIRE FIGHTING PROCEDURES : NONE . UNUSUAL FIRE AND EXPLOSION HAZARDS : NONE HAZARDOUS REACTIVITY STABILITY: STABLE POLYMERIZATION: WILL NOT OCCUR CONDITIONS TO AVOID: NONE MATERIALS TO AVOID: STRONG ACIDS HAZARDOUS DECOMPOSITION PRODUCTS : NONE SPILL, LEAK AND DISPOSAL PROCEDURES ACTION TO TAKE FOR SPILLS OR LEAKS : WEAR PROTECTIVE EQUIPMENT INCLUDING RUBBER BOOTS, RUBBER GLOVES, RUBBER APRON AND A 941078 MSDS NO: 002-93 TWIN-KEM INTERNATIONAL, INC. PAGE : 04 MATERIAL SAFETY DATA SHEET PRODUCT: SCALE-NIX 160 SELF-CONTAINED BREATHING APPARATUS IN THE PRESSURE DEMAND MODE OR A SUPPLIED-AIR RESPIRATOR. IF THE SPILL OR LEAK IS SMALL, A FULL FACEPEICE AIR-PURIFYING CARTRIDGE RESPIRATOR EQUIPPED FOR ORGANIC VAPORS MAY BE SATISFACTORY. IN ANY EVENT, ALWAYS WEAR EYE PROTECTION. EXTINGUISH ALL IGNITION SOURCES. FOR SMALL SPILLS OR DRIPS, MOP OR WIPE UP AND DISPOSE OF IN DOT-APPROVED WASTE CONTAINERS . FOR LARGE SPILLS, CONTAIN BY DIKING WITH SOIL OR OTHER NON-COMBUSTIBLE SORBENT MATERIAL AND THEN PUMP INTO DOT-APPROVED WASTE CONTAINERS; OR ABSORB WITH NON-COMBUSTIBLE SORBENT MATERIAL AND PLACE RESIDUE IN DOT-APPROVED CONTAINERS . KEEP OUT OF SEWERS, STORM DRAINS, SURFACE WATERS AND SOIL. COMPLY WITH ALL APPLICABLE GOVERNMENTAL REGULATIONS ON SPILL REPORTING, AND HANDLING AND DISPOSAL OF WASTE . DISPOSAL METHODS: DISPOSE OF CONTAMINATED PRODUCT AND MATERIALS USED IN CLEANING UP SPILLS OR LEAKS IN A MANNER APPROVED FOR THIS MATERIAL. CONSULT APPROPRIATE FEDERAL, STATE, AND LOCAL REGULATORY AGENCIES TO ASCERTAIN PROPER DISPOSAL PROCEDURES . NOTE: EMPTY CONTAINERS CAN HAVE RESIDUES, GASES AND MISTS AND ARE SUBJECT TO PROPER WASTE DISPOSAL, AS ABOVE . SPECIAL PRECAUTIONS STORAGE AND HANDLING PRECAUTIONS : STORE IN A DRY, WELL- VENTILATED PLACE AWAY FROM COMBUSTIBLE MATERIALS . KEEP CONTAINER TIGHTLY CLOSED WHEN NOT IN USE . DO NOT USE PRESSURE TO EMPTY CONTAINER. WASH THOROUGHLY AFTER HANDLING. DO NOT GET IN EYES, ON SKIN, OR ON CLOTHING. REPAIR AND MAINTENANCE PRECAUTIONS : NONE . OTHER PRECAUTIONS: CONTAINERS, EVEN THOSE THAT HAVE BEEN EMPTIED, WILL RETAIN PRODUCT RESIDUE AND VAPORS . ALWAYS OBEY HAZARD WARNINGS AND HANDLE EMPTY CONTAINERS AS IF THEY WERE FULL. 9410'78 MSDS: 002-93 TWIN-KEM INTERNATIONAL, INC. PAGE : 05 MATERIAL SAFETY DATA SHEET PRODUCT: SCALE-NIX 160 NOTICE ** TWIN-KEM INTERNATIONAL, INC. EXPRESSLY DISCLAIMS ALL EXPRESS OR IMPLIED WARRANTIES OF MERCHANTIBILITY AND FITNESS FOR A PARTICULAR PURPOSE . WITH RESPECT TO THE PRODUCT OR INFORMATION PROVIDED. HEREIN. ** ALL INFORMATION CONTAINED HEREIN IS BASED UPON DATA OBTAINED FROM THE MANUFACTURER AND/OR RECOGNIZED TECHNICAL SOURCES. WHILE THE INFORMATION IS BELIEVED TO BE ACCURATE, T- KI MAKES NO REPRESENTATIONS AS TO ITS ACCURACY OR SUFFICIENCY. CONDITIONS OF USE ARE BEYOND T-KI ' S CONTROL AND THEREFORE USERS ARE RESPONSIBLE TO VERIFY THIS DATA UNDER THEIR OWN OPERATING CONDITIONS TO DETERMINE WHETHER THE PRODUCT IS SUITABLE FOR THEIR PARTICULAR PURPOSES AND THEY ASSUME ALL RISKS OF THEIR OWN USE, HANDLING, AND DISPOSAL OF THE PRODUCT, OR FROM THE PUBLICATION OR USE OF, OR RELIANCE UPON, INFORMATION CONTAINED HEREIN, . THIS INFORMATION RELATES ONLY TO THE PRODUCT DESIGNATED HEREIN, AND DOS NOT RELATE TO ITS USE IN COMBINATION WITH ANY OTHER MATERIAL OR IN ANY OTHER PROCESS . ********* END OF MSDS ******** 941078 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE : 01 MATERIAL SAFETY DATA SHEET EFFECTIVE DATE : 04/12/94 WRIGHT' S DISPOSAL, INC. 13050 WELD COUNTY ROAD #16 FT. LUPTON, CO 80621 PHONE (303) 857-0655 ************************************************************* EMERGENCY ASSISTANCE FOR EMERGENCY ASSISTANCE INVOLVING CHEMICALS CALL: CHEMTREC (800-424-9300) ************************************************************* PRODUCT AND SALES INFORMATION TWIN-KEM INTERNATIONAL, INC. 4220 S . ALLISON STREET, LAKEWOOD PHONE: (303) 986-6440 FAX: ( 303 ) 988-8202 ************************************************************* * SECTION I : GENERAL INFORMATION ************************************************************* PRODUCT NAME: SIO-NIX 500 PRODUCT CLASS: MIXTURE PRECAUTIONS: FLAMMABLE; CORROSIVE REFER TO BILL OF LADING OR CONTAINER LABEL FOR DOT OR OTHER TRANSPORTATION HAZARD CLASSIFICATION IF ANY. ************************************************************* * SECTION II: HAZARDOUS INGREDIENTS ************************************************************* INGREDIENT (CAS #) OSHA PEL ACGIH TLV OTHER (PPM) (PPM) GLUTERALDEHYDE ( 111-30-8) 0 . 2 0 . 2 14% n-ALKYL DIMETHYL BENZYL None Established AMMOMIUN CHOLRIDE( 139-08-2 ) 2 . 5% ETHANOL ( 64-17-5) 1000 1000 1% WATER (7732-18-5) None Established 82% METHANOL ( 67-56-1) 200 200 0 .5% h 941078 MSDS : 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE: 02 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ************************************************************* * SECTION 111: PHYSICAL/CHEMICAL DATA ************************************************************* BOILING POINT, 760mm Hg: -100 . 5 C ( -213 F) SPECIFIC GRAVITY(H2O=1 ) : 1 . 035 EVAPORATION RATE (Butyl Acetate = 1 ) : 1 . 03 VAPOR DENSITY (Air = 1 ) : 1 . 1 VAPOR PRESSURE at 20 ' C: 17 mmHg FREEZING POINT: -3 . 1 C ( 26 . 4 F) APPEARANCE: TRANSPARENT PALE YELLOW PHYSICAL STATE: LIQUID WEIGHT PER GALLON: 8 . 61 LBS ************************************************************* * SECTION IV: FIRE AND EXPLOSION DATA ************************************************************* FLASH POINT (TEST METHODS) : NONE TAG CLOSED CUP ASTM D 56 EXPLOSIVE LIMITS : IN AIR LOWER: NOT DETERMINED AQUEOUS SYSTEM % by volume: UPPER: NOT DETERMINED AQUEOUS SYSTEM EXTINGUISHING MEDIA: NON-FLAMMABLE (AQUEOUS SOLUTION) : AFTER WATER EVAPORATES, REMAINING MATERIAL WILL BURN. USE ALCOHOL TYPE OR ALL- PURPOSE-TYPE FOAM, APPLIED BY MANUFACTURER' S RECOMMENDED TECHNIQUES FOR LARGE FIRES . USE CARBON DIOXIDE OR DRY CHEMICAL MEDIA FOR SMALL FIRES . SPECIAL FIRE FIGHTING PROCEDURES : SELF-CONTAINED BREATHING APPARATUS AND PROTECTIVE CLOTHING SHOULD BE WORN IN FIGHTING UNUSUAL FIRE AND EXPLOSION HAZARDS: WHEN THIS MATERIAL IS EXPOSED TO EXTREME HEAT, AS IN A FIRE, IT MAY POLYMERIZE AND RUPTURE A CLOSED CONTAINER. ************************************************************* * SECTION V: REACTIVITY DATA ************************************************************* STABILITY: STABLE 9410'78 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE: 03 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 5OO ************************************************************ HAZARDOUS POLYMERIZATION: WILL NOT OCCUR INCOMPATIBILITY (MATERIALS TO AVOID) STRONG ALKALIS AND ACIDS CATALYZE AN ALDOL-TYPE CONDENSATION (EXOTHERMIC, BUT NOT EXPECTED TO BE VIOLENT) . CONDITIONS TO AVOID: AVOID HIGH TEMPERATURES AND EVAPORATION OF WATER. TEMPERATURES ABOVE 100 DEGREES C. ALTHOUGH POLYMERIZATION MAY OCCUR, IT IS NOT VIOLENT. HAZARDOUS COMBUSTION OR DECOMPOSITION PRODUCTS : BURNING CAN PRODUCE THE FOLLOWING PRODUCTS : * CARBON MONOXIDE AND/OR CARBON DIOXIDE * CARBON MONOXIDE IS HIGHLY TOXIC IF INHALED; CARBON DIOXIDE IS SUFFICIENT CONCENTRATION CAN ACT AS AN ASPHYXIANT. ************************************************************* * SECTION VI: HEALTH HAZARD DATA ************************************************************* EFFECTS OF OVEREXPOSURE/EMERGENCY AND FIRST AID PROCEDURES . EXPOSURE LIMITS : GLUTERALDEHYDE : 0 . 2 PPMV CEILING, OSHA & ACGIH METHANOL: 200 PPM TWA(SKIN) , OSHA & ACGIH 250 PPM STEL(SKIN) , OSHA & ACGIH ETHANOL: 1000 PPN RWA, OSHA & CGIH EFFECTS OF SINGLE EXPOSURE: EYES: LIQUID WILL CAUSE A SEVERE AND PERSISTENT CONJUNCTIVITIS, SEEN AS EXCESS REDNESS AND MARKED SWELLING OF THE CONJUNCTIVE WITH PROFUSE DISCHARGE . SEVERE CORNEAL INJURY MAY DEVELOP, WHICH COULD PERMANENTLY IMPAIR VISION IF PROMPT FIRST-AID AND MEDICAL TREATMENT ARE NOT OBTAINS . VAPOR WILL CAUSE STINGING SENSATIONS IN THE EYE WITH EXCESS TEAR PRODUCTION, BLINKING, AND POSSIBLY A SLIGHT REDNESS OF THE CONJUNCTIVE . INHALATION: VAPOR IS IRRITATING TO THE RESPIRATORY TRACT, CAUSING STINGING SENSATIONS IN THE NOSE AND THROAT, DISCHARGE FORM THE NOSE, POSSIBLY BLEEDING FROM THE NOSE, COUGHING, CHEST MSDS: 9410Th 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE : 04 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ************************************************************ DISCOMFORT AND TIGHTNESS, DIFFICULTY WITH BREATHING, AND HEADACHE . SWALLOWING: MODERATELY TOXIC. MAY CAUSE MODERATE TO MARKED IRRITATION OR CHEMICAL BURNS OF THE MOUTH, THROAT CHEST, AND ABDOMEN, NAUSEA, VOMITING, DIARRHEA, FAINTNESS, DROWSINESS, WEAKNESS, THIRST, CIRCULATORY COLLAPSE, AND COMA. SKIN ABSORPTION: PROLONGED OR WIDESPREAD CONTACT MAY RESULT IN THE ABSORPTION OF POTENTIALLY HARMFUL AMOUNTS OF MATERIAL. MEDICAL CONDITIONS AGGRAVATED BY OVEREXPOSURE : SKIN CONTACT MAY AGGRAVATE AN EXISTING DERMATITIS . inhalation OF MATERIAL MAY AGGRAVATE ASTHMA AND INFLAMMATORY OF FIBROTIC PULMONARY DISEASES. EFFECTS OF REPEATED OVEREXPOSURE : REPEATED SKIN CONTACT MAY CAUSE A CUMULATIVE DERMATITIS. SEE SECTION II FOR HAZARDOUS INGREDIENTS PRESENT IN THIS PRODUCT AND THEIR CORRESPONDING THRESHOLD LIMIT VALUES . SIGNIFICANT LABORATORY DATA WITH POSSIBLE RELEVANCE TO HUMAN HEALTH HAZARD EVALUATION: LABORATORY STUDIES HAVE SHOWN THAT GLUTERALDEHYDE IS NOT TETROGENIC, AND SEVERAL STUDIES HAVE SHOWN THE MATERIAL NOT TO BE A MUTAGEN. PRELIMINARY, AS YET NOT QUALITY ASSURED, HISTOPATHOLOGICAL FINDINGS IN THE 24- MONTH SACRIFICE OF A COMBINED ONCOGENICITY/CHRONIC TOXICITY STUDY IN FISCHER 344 RATS GIVEN GLUTERALDEHYDE IN DRINKING WATER (50, 250, AND 1000PPM) SHOWED AN INCREASE IN THE INCIDENCE OF THE SPONTANEOUSLY OCCURRING LARGE GRANULAR CELL LYMPHOCYTIC LEUKEMIA (LGL) AT ALL DOSAGES COMPARED WITH THE CONTROLS ONLY FOR THE FEMALE RATS . MALE RATS HAD THE SAME INCIDENCE IN CONTROLS AND AT ALL LEVELS OF EXPOSURES . SINCE 941078 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE : 05 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ************************************************************ ******************************************************* FOR ADDITIONAL MEDICAL INFORMATION, CALL 1-800-228-5635 ******************************************************* THE INCIDENCE OF THIS LEUKEMIA WAS LOW IN THE CONTROL FEMALE RATS, COMPARISON WITH OTHER CONTROL DATA AND FURTHER STATISTICAL ANALYSES ARE CURRENTLY BEING UNDERTAKEN IN ORDER TO FURTHER DEFINE THE RELEVANCE OF THIS STUDY. THE INTERNATIONAL AGENCY FOR RESEARCH ON CANCER ( IARC) HAS DETERMINED THAT THE CONSUMPTION OF ALCOHOLIC BEVERAGES IS CAUSALLY RELATED TO THE OCCURRENCE OF MALIGNANT TUMORS OF THE ORAL CAVITY, PHARYNX , LARYNX, ESOPHAGUS AND LIVER IN HUMANS . THE CARCINOGENIC RESPONSE ATTRIBUTED TO DRINKING ALCOHOLIC BEVERAGES HAS NOT BEEN VERIFIED IN STUDIES WITH LABORATORY ANIMALS . ESTABLISHED USES OF DENATURED ETHANOL AND NON- BEVERAGE USES OF PURE ETHANOL ARE NOT CONSIDERED TO POSE ANY SIGNIFICANT CANCER HAZARD. OTHER EFFECTS OF OVEREXPOSURE : MAY CAUSE SKIN SENSITIZATION IN A SMALL PORTION OF INDIVIDUALS AND PRESENT AS AN ALLERGIC CONTACT DERMATITIS . THIS USUALLY RESULTS FROM CONTACT WITH THE LIQUID, BUT OCCASIONALLY THERE MAY BE A REACTION TO GLUTERALDEHYDE VAPOR. EMERGENCY AND FIRST AID PROCEDURES: SWALLOWING: DO NOT INDUCE VOMITING. DO NOT GIVE ANYTHING TO DRINK. OBTAIN MEDICAL ATTENTION WITHOUT DELAY. SKIN: IMMEDIATELY REMOVE CONTAMINATED CLOTHES AND SHOES . WASH SKIN WITH SOAP AND WATER. . OBTAIN MEDICAL ATTENTION. WASH CLOTHING BEFORE REUSE . DISCARD CONTAMINATED LEATHER ARTICLES SUCH AS SHOES AND BELT. INHALATION: REMOVE TO FRESH AIR. GIVE ARTIFICIAL RESPIRATION IF NOT BREATHING. IF BREATHING IS DIFFICULT, OXYGEN MAY BE GIVEN BY QUALIFIED PERSONNEL. OBTAIN MEDICAL ATTENTION. 941078 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE: 06 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ************************************************************ EYES : IMMEDIATELY FLUSH WITH WATER AND CONTINUE WASHING FOR AT LEAST 15 MINUTES . OBTAIN MEDICAL ATTENTION WITHOUT DELAY, PREFERABLY FROM AN OPHTHALMOLOGIST. NOTES TO PHYSICIAN: THE HAZARDS OF THIS MATERIAL ARE DUE MAINLY TO ITS SEVERELY IRRITANT PROPERTIES ON SKIN AND MUCOSAL SURFACES . MODERATELY TOXIC BY SWALLOWING. MODERATELY TOXIC BY ABSORPTION ACROSS THE SKIN. DUE TO THE SEVERELY IRRITATING OR CORROSIVE NATURE OF THE MATERIAL, SWALLOWING MAY LEAD TO ULCERATION AND INFLAMMATION OF THE UPPER ALIMENTARY TRACT WITH HEMORRHAGE AND FLUID LOSS. ALSO, PERFORATION OF THE ESOPHAGUS OR STOMACH MAY OCCUR, LEADING TO MEDIATITIS OR PERITONITIS AND THE RESULTANT COMPLICATIONS . THE STOMACH SHOULD BE EVACUATED CAREFULLY IN CASE OF INGESTION. ANY MATERIAL ASPIRATED DURING VOMITING MAY CAUSE LUNG INJURY. THEREFORE, EMESIS SHOULD NOT BE INDUCED MECHANICALLY OF PHARMACOLOGICALLY. IF IT IS CONSIDERED NECESSARY TO EVACUATE THE STOMACH CONTENTS, THIS SHOULD BE DONE BY MEANS LEAST LIKELY TO CAUSE ASPIRATION (E .G. GASTRIC LAVAGE AFTER ENDOTRACHEAL INTUBATION) . ************************************************************* * SECTION VII: SPILL OR LEAK PROCEDURES * ************************************************************* STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: WEAR SUITABLE PROTECTIVE EQUIPMENT. TOXIC TO FISH; AVOID DISCHARGE TO NATURAL WATERS . VERY LOW CONCENTRATIONS ( 10 PPM OR LEES) CAN BE DEGRADED IN A BIOLOGICAL TREATMENT SYSTEM. THUS, SMALL SPILLS CAN BE FLUSHED WITH LARGE QUANTITIES OF WATER A WITH WATER. LARGE QUANTITIES OF "SLUGS" CAN BE HARMFUL TO 941078 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE : 07 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ***********************************************************.* THE TREATMENT SYSTEM. THUS, LARGE SPILLS SHOULD BE COLLECTED FOR DISPOSAL, IT MAY ALSO BE POSSIBLE TO DECONTAMINATE SPILLED MATERIAL BY CAREFUL APPLICATION OF AQUEOUS SODIUM HYDROXIDE OR DIBASIC AMMONIUM PHOSPHATE SOLUTION. DEPENDING ON CONDITIONS, CONSIDERABLE HEAT AND FUMES CAN BE LIBERATED BY THE DECONTAMINATION REACTION. WASTE DISPOSAL METHOD ATOMIZE INTO A VERY HOT INCINERATOR FIRE OR MIX WITH A FLAMMABLE SOLVENT, AND INCINERATE WHERE PERMITTED UNDER APPROPRIATE FEDERAL, STATE, AND LOCAL REGULATIONS . HIGH WATER CONTENT MAY DAMPEN FLAME . ************************************************************* * SECTION VIII : PROTECTIVE MEASURES ************************************************************* EYE PROTECTION: WEAR FULL FACE SHIELD OR GOGGLES WHEN HANDLING. PROTECTIVE GLOVES : RUBBER NITRILE (NBR) BUTYL POLYETHYLENE RESPIRATORY PROTECTION ( SPECIFY TYPE) : USE SELF-CONTAINED BREATHING APPARATUS IN HIGH VAPOR CONCENTRATIONS . IF SELF-CONTAINED BREATHING APPARATUS IS NOT AVAILABLE, A MSHA/NIOSH APPROVED AIR PURIFYING RESPIRATOR EQUIPPED WITH AN ORGANIC VAPOR CARTRIDGE SHOULD BE USED. OTHER PROTECTIVE EQUIPMENT: CHEMICAL APRON. AN EYE WASH STATION AND SAFETY SHOWER SHOULD BE NEAR THE WORK AREA. RUBBER BOOTS . 941078 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE : 08 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ************************************************************ VENTILATION: GENERAL (MECHANICAL) ROOM VENTILATION IS EXPECTED TO BE SATISFACTORY WHERE THIS PRODUCT IS STORED AND HANDLED IN CLOSED EQUIPMENT. ************************************************************* * SECTION IX: SPECIAL PRECAUTIONS. ************************************************************* PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE: DANGER: CORROSIVE CAUSES IRREVERSIBLE EYE DAMAGE . CAUSES SKIN BURNS MAY BE FATAL IF SWALLOWED OR ABSORBED THROUGH THE SKIN. HARMFUL IF INHALED MAY CAUSE SKIN SENSITIZATION. DO NOT GET IN EYES, ON SKIN, ON CLOTHING. AVOID BREATHING VAPOR. DO NOT SWALLOW WEAR GOGGLES, PROTECTIVE CLOTHING, AND RUBBER GLOVES . WASH THOROUGHLY WITH SOAP AND WATER AFTER HANDLING. REMOVE CONTAMINATED CLOTHING AND WASH BEFORE REUSE . FOR INDUSTRY USE ONLY OTHER PRECAUTIONS : LABORATORY STUDIES, USING AN ODOR TEST PANEL, INDICATED GLUTARALDERHYDE VAPORS IN AIR MAY BE " IRRITATING" TO HUMANS AT ABOUT 0 . 3PPM IN AIR: THE TLV HAS BEEN ESTABLISHED AS 0 . 2 PPM CEILING. THUS, IF VAPORS ARE CONCENTRATED ENOUGH TO BE IRRITATING, THE TLV IS PROBABLY BEING EXCEEDED. MUST NOT BE USED IN THE FORM OF A SPRAY OR AEROSOL. ************************************************************ 941078 MSDS: 001-94 TWIN-KEM INTERNATIONAL, INC. PAGE : 09 MATERIAL SAFETY DATA SHEET PRODUCT: BIO-NIX 500 ************************************************************ NEITHER THIS DATA SHEET NOR ANY STATEMENT CONTAINED HEREIN GRANTS OR EXTENDS ANY LICENCE, EXPRESS OR IMPLEID, IN CONNECTION WITH PATENTS OR PENDING WHICH MAY BE THE PROPERTY OF THE MANUFACTURER OR OTHERS . THE INFORMATION IN THIS DATA SHEET HAS BEEN ASSEMBLED BY THE MANUFACTURER BASED ON ITS OWN STUDIES AND ON THE WORK OF OTHERS . THE MANUFACTURER MAKES NO WARRANTIES, EXPRESS OR IMPLIED, AS TO THE ACCURACY, COMPLETENESS, OR ADEQUACY OF THE INFORMATION CONTAINED HEREIN. THE MANUFACTURER SHALL NOT BE LIABLE (REGARDLESS OF FAULT) TO THE VENDER, THE VENDEE ' S EMPLOYEES, OR ANYONE FOR ANY DIRECT, SPECIAL OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH THE ACCURACY, COMPLETENESS, ADEQUACY, OR FURNISHING OF SUCH INFORMATION. 94107 STATE OF COLORADO Roy Romer,Governor pc'eo Patricia A.Nolan,MD,MPH,Executive Director .4,8r-m- Dedicated to protecting and improving the hea/th and environment of the people of Colorado `"e ^' * •' 09j** 4300 Cherry Creek Dr.S. Laboratory Building J Eciti L 4'.":7€4 a, ,:. r Denver,Colorado 80222-1530 42W E.11th Avenue li\V Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 I Iy JUL 2 1994 lorado Department Jul 21 1994 I of Public Health Y f and Environment •Weld County Board of County Commissioners """ "'"°lanninn County Commissioners Office 915 10th Street Greeley, Colorado 80632 RE: Certificate of Designation Application Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Commissioners: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Wright's Disposal Inc.'s Certificate of Designation Application to operate a liquid waste disposal facility in Weld County. The Division hereby determines that, based on information submitted by the applicant and subsequent correspondence, and contingent the requirements stated in the Division's July 19, 1994 letter to Mr. Martin Wohnlich being adequately addressed, all requirements of the Solid Wastes Disposal Sites and Facilities Act (C.R.S. 30-20-1 et seq.) have been met. A copy of the July 19, 1994 letter is enclosed. This determination serves as recommendation to the Weld County Board of County Commissioners that a Certificate of Designation for solid waste disposal as documented in the referenced Wright's Disposal submittals may be granted for this facility. I hope this letter clearly states the Division's position on the status of this facility. If you have any questions regarding this matter, please contact me at (303) 692-3462. Sincere y, , C.-- 7 ( / ( ,„---2 -I- / —7 QC! Iz. L ��,, i r /L.- Step11V�en\,glldeman Tenn F. Mallory Gelogical Engineer ! Section Chief Solid Waste Section Solid Waste Section Hazardous Materials Hazardous Materials and Waste Management Division and Waste Management Division enclosure cc: Martin Wohnlich, Wright's Disposal, Inc. w/o enclosure Kenneth Lind, Lind, Lawrence, and Ottenhoff w/o enclosure Keith Schuett, Weld County Planning Department w/ enclosure Trevor Jiricek, Weld County Department of Health w/o enclosure John Carson, US Environmental Protection Agency W/o enclosure Patricia Beaver, Colorado Oil and Gas Conservation Commission w/o enclosure File: SW/WLD/WRI/2 941078 # "�� EXXHIBIT 4 STATE OF COLORADO OF cote Roy Romer,Governor `° -- Patricia A.Nolan,MD,MPH,Executive Director N Dedicated to protecting and improving the health and environment of the people of Colorado `'' i, 4300 Cherry Creek Dr.S. Laboratory Building *1876 Denver,Colorado 80222-1530 4210 E.11th Avenue Phone(3 03)69 2-2 000 Denver,Colorado 80220-3716 303)691-4700 ( Colorado Department of Public Health and Environment July 19, 1994 Mr. Martin Wohnlich Wright's Disposal, Inc. 2323 South Wadsworth Blvd., Suite 103 • Denver, Colorado 80227 RE: Certificate of Designation Application Technical Review Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Mr. Wohnlich: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Hepworth-Pawlak Geotechnical, Inc.'s letter of July 18, 1993 regarding installation of ground water monitoring wells at the Wright's Disposal facility. These ground water monitoring wells were installed in response to concerns expressed in the Division's June 9, 1994 letter. Based on a review of the information provided, the Division finds that the three wells as installed (designated OW-1, OW-2, and OW-3) will serve to satisfy the Division's request for installation of a ground water monitoring system. As we have discussed, the last remaining concerns of the Division have to do with the parameter list for monitoring and the monitoring frequency. The Division requires that the minimum parameter list consist of the constituents listed in Appendix IA of the Solid Waste Regulations (6 CCR 1007-2) and benzene, ethyl benzene, toluene, and xylene, (BTEX) and Total Petroleum Hydrocarbons (TPH). All sampling and analyses must follow standard accepted protocols and utilize EPA approved methods. A copy of Appendix I of the Regulations is enclosed for your reference. The Division requires that individual samples be obtained from each well and analyzed on a semi-annual basis (twice per year). In addition to obtaining samples for analysis, it will be necessary to determine the elevation of water in each well at each sampling event and use this information to determine the direction of flow and the magnitude of the hydraulic gradient. All analytical results and other monitoring information must be submitted to the Division and Weld County Health Department after each sampling event. As all concerns of the Division regarding the Certificate of Designation Application for this facility have now been met, a letter will be sent to the Weld County Planning Department recommmending approval of Wright's Disposal's Application for a Certificate of Designation. • I hope this letter clearly states the Division's position on the status of this facility. If you have 941078 Mr. Martin Wohnlich July 19, 1994 Page 2 any questions regarding this matter, please contact me at (303) 692-3462. Sincerely, 1 it Stephe Lau an Geolog al Engineer Solid Waste Section Hazardous Materials and Waste Management Division enclosure cc: Kenneth Lind, Lind, Lawrence, and Ottenhoff Trevor Jiricek, Weld County Department of Health w/copy of July 18, 1994 letter John Carson, US Environmental Protection Agency w/copy of July 18, 1994 letter Patricia Beaver, Colorado Oil and Gas Conservation Commission File: SW/WLD/WRI/2 941078 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH ��°F;6?..\ Dedicated to protecting and improving the health and environment of the people of Colorado + G::7 i + 4300 Cherry Creek Dr.5. Laboratory Building •tee' Denver,Colorado 80222-1530 4210 E.11th Avenue Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 Roy Romer Governor June 9, 1994 Patricia A.Nolan,MD,MPH Executive Director Mr. Martin Wohnlich Wright's Disposal, Inc. PT1\' . 2323 South Wadsworth, Suite 103 I JUN 1 . 1994 1 Denver, Colorado 80227 �I �_ RE: Certificate of Designation Application Wald County Planning Technical Review Wright's Disposal, Inc. Liquid Waste Facility Weld County, Colorado Dear Mr. Wohnlich: The Solid Waste Section of the Hazardous Materials and Waste Management Division (the Division) has completed its review of Wright's Disposal's letter of May 24, 1994 which contained a response to concerns of the Division regarding the application for a Certificate of Designation for this facility. This letter contained specific responses to concerns detailed in the Division's letter of May 19, 1994. Based on a review of the submitted information, the Division has the following comments: 1. The revised application documentation states that all Class I wastes will be subjected to the same processes prior to injection as Class II (oil field) wastes. It will therefore be impossible to segregate secondary waste related to oil field activities from that related to other non-exempt solid wastes. For this reason, all secondary wastes generated by the facility will be classified as solid waste, and shall be removed from the site and disposed of accordingly at an approved facility(ies). 2. With regard to the information provided on spill containment structures, as design documents are not available for these structures, it is not possible for the Division to verify their integrity. It will be necessary to document that all structures designed to contain spills have a permeability of 1 x 10-7 cm/sec or less. Of specific concern is the enclosure that is intended to contain a spill from the eight 400 barrel holding tanks. Discussion of the containment structures on page 13 of the Application implies that this containment has a continuous concrete floor. Based on our discussion on May 23, 1994, this containment has concrete walls and a soil floor. If all spill containment structures cannot be shown to meet the necessary permeability, three options exist: (1) an adequate soil liner be constructed, EXHIBIT Mr. Martin Wohnlich June 9, 1994 Page 2 (2) a adequate concrete floor be constructed, or (3) an adequate ground water monitoring system be designed and implemented. 3. It will be necessary to provide copies of calculations used to determine the capacity of the containment around the eight 400 barrel holding tanks. A plan for immediate removal of liquids from this containment must be developed and incorporated in to the design and operations plan. This plan must include a provision for installation and monitoring of a sump within the containment area, and use of this sump to remove waste fluids in the event of a spill. 4. With regard to financial assurance for the closure of the facility, it will be necessary to develop an estimate of the closure costs and maintain funds in that amount available through one of the financial vehicles specified in Section 1.8 of the Regulations. As stated in the Division's letter of May 19, 1994, financial assurance will not be mandatory until April, 1995. These comments must be addressed in a comprehensive written response prior to the Division completing its technical review of this application. Submittal of the requested information and responses to the Division's concerns may bring up other concerns, and as such further information may be requested. I hope this letter clearly states the Division's position on the status of this facility. If you have any questions regarding this matter, please contact me at (303) 692-3462. Sincerel , i Step La d mangy Geological Engineer Solid Waste Section Hazardous Materials and Waste Management Division cc: Kenneth Lind, Lind, Lawrence, and Ottenhoff Keith Schuett, Weld County Planning Department Trevor Jiricek, Weld County Department of Health John Carson, United States Environmental Protection Agency Patricia Beaver, Colorado Oil and Gas Conservation Commission File: SW/WLD/WRI/2 941018 1 DEPARTMENT OF HEALTH 1517• 16 AVENUE COURT j GREELEY, COLORADO 80631 O ADMINISTRATION (303)353-0586 HEALTH PROTECTION(303)353-0635 COMMUNITY HEALTH(303)353-0639 COLORADO April 20, 1994 Steve Laudeman Colorado Department of Health 4300 Cherry Creek Drive, South Denver, Colorado 80222-1530 Dear Steve: The Environmental Protection Division of the Weld County Health Department has reviewed the Wright's Disposal, Inc. application for Use by Special Review and Certificate of Designation. As we discussed, in the interest of time efficiency, our Division is submitting the following questions/comments to be included with any questions/comments your Division may have pertaining to this application. Our Division would like to see additional information on the following: 1) Page 5 of the USR application states that "approximately 160 pounds of boxes and filters are used per week." Please inform the Division of what additional analysis, if any, is necessary to adequately characterize the filters so that they may be disposed as a non-hazardous solid waste. 2) Page 2 of the C.D. application indicates that "retainer walls of concrete" exist around all storage tanks, and during a site visit the operator indicated that there is a concrete base as well. The operator also indicated that water from inside the retaining walls in captured in a "french drain". If in fact the retaining walls and floor are built of concrete the existence of the "french drain" seems to be redundant. Please provide engineered documentation of the retaining walls and floor which demonstrate their construction (this should include capacity) . In addition, provide the specifications of the earthen wall surrounding the skim/surge tank. 3) Page 3, section 2.2.6, of the C.D. application discusses "records of gas vapors". Please provide records demonstrating that gas vapors have not exceeded 5 PPM. 4) Page 13, section 4.7.13, of the C.D. application discusses spills within the retainer walls. How will moisture accumulated as the result of natural moisture events (i.e. snow, rain) be managed? gg EXHIBIT :3 4 , is Wrights Disposal Comments Page 2 In addition, the Division has the following questions/concerns which may be in need of addressing: 1) Page 17, section 7.3, states that the applicant does not feel the solid waste disposal site and facility registration fee applies to this facility. This would seem to be applicable. 2) Will the applicant be required to post financial assurance in accordance with the Solid Waste Regulations? 3) Will a fence and/or gate be required in accordance with the Solid Waste Regulations? These conclude the Division's comments at this time. If you have any questions, please call me at (303) 353-0635. Sincerely, y ,i ly" " y fie Trevor Jiricdk, Supervisor Environmental Protection Services tj/ cc: Keith Schuett, Weld County Planning Department APR 2 2 1994 'void County Planning 54 ' ' �,da 941078 AR231a2J0 ORDINANCE NO. 164-A IN THE MATTER OF AMENDING ORDINANCE NO. 164 TO ESTABLISH A SURCHARGE TO COVER THE ACTUAL AND NECESSARY COSTS OF FINANCING SOLID WASTE MANAGEMENT IN WELD COUNTY, COLORADO, AND DECLARING AN EMERGENCY BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF WELD, STATE OF COLORADO: WHEREAS, The Board of County Commissioners of the County of Weld, State of Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, pursuant to the Weld County Home Rule Charter Article XVI, Section 16-11 and C.R.S. Section 30-20-115, the Board of County Commissioners may collect a surcharge to be added to fees received by operators of solid waste disposal sites and facilities in order to offset the impacts to Weld County and its residents resulting from the disposal, siting, and operation of waste disposal sites and facilities, and WHEREAS, certain small quantities of hazardous waste generated by residential uses (commonly known as household hazardous waste) , which are exempt under federal and state law from regulation as hazardous waste, may be being disposed of at solid waste sites and facilities within Weld County, and WHEREAS, in the absence of an extensive education, collection, and inspection program, household hazardous wastes and other hazardous wastes are not likely to be intercepted to avoid using solid waste disposal sites and facilities for disposal, and WHEREAS, additional programs of education, source reduction, separation, and marketing are necessary to improve the effectiveness of recycling programs within Weld County, Colorado, and WHEREAS, it is in the best interests of the operators, users, governmental entities, and present and future residents of Weld County that hazardous waste be intercepted and disposed of properly other than in solid waste disposal facilities (even where they may be legally disposed of in solid waste facilities as exempt from regulation as hazardous waste) and that recyclables be separated and directed toward appropriate markets rather than being placed in solid waste sites and facilities for permanent disposal, and WHEREAS, the current intent of Ordinance No. 164 and the Weld County Home Rule Charter, Article XVI, Section 16-11, expressed generally, would allow expenditure of funds which would support programs to intercept and encourage proper disposal of hazardous wastes and encourage recycling and reuse of of wastes and that the Board of County Commissioners wishes to expressly . 913 the use of the funds in the solid waste sites and facilities fu , forsueh " purposes, and NOV ` , 1592 L 1358 REC 02310230 11/06/92 15 :48 $0 .00 1/003 F 03 i MARY ANN FEUERSTEIN CLERK & RECORDER WELD CO, CO CC---- Pk/ HR, RE: ORDINANCE #164-A PAGE 2 WHEREAS, the impacts to Weld County in establishing hazardous waste programs and recycling programs to prevent illegal and unsafe disposal of hazardous wastes and wasteful disposal of recyclables requires an increase in the amount of the surcharge assessed pursuant to Ordinance No. 164, and WHEREAS, an emergency exists in that a funding source needs to be established prior to setting the budget for fiscal year 1993 and collections commenced so that cash flow is established to fund necessary hazardous waste and recycling programs by Weld County. NOW, THEREFORE, BE IT ORDAINED by the Board of County Commissioners of Weld County, Colorado that Section 2 of Weld County Ordinance No. 164 be amended to read as follows: There is, hereby, established a surcharge in the amount of ten percent (10%) to be added to all disposal fees received by any operator operating a solid waste disposal site and facility or transfer station within Weld County, Colorado including areas within corporate limits of municipalities. "Solid Waste Disposal Site and Facility" shall mean any facility which is required, pursuant to applicable provisions of state law, to obtain a certificate of designation from the Weld County Board of County Commissioners or approval by a city, county, or town (collectively known as "municipalities") prior to its operation. BE IT FURTHER ORDAINED that Section 5 of Ordinance 164 be amended to add an additional sentence to read as follows: "This section is intended to allow use of such Fund to support programs that encourage recycling of wastes and proper handling of hazardous wastes." BE IT FURTHER ORDAINED by the Board that an emergency exists which requires that this Ordinance No. 164-A is declared to be an emergency ordinance under the provisions of Section 3-14 of the Weld County Home Rule Charter. BE IT FURTHER ORDAINED that the effective date of this Ordinance shall be as provided under Article III, Section 3-14 of the Weld County Home Rule Charter but that the additional 5% surcharge shall not commence to accrue until November 1, 1992, which surcharge will be payable by operators of facilities prior to December 20, 1992, and BE IT FURTHER ORDAINED that should any operator, in good faith, be unable to meet the statutory or County regulatory requirement that notice of any change in rates to solid waste disposal site and facility be published prior to imposition of a changed fee, then said operator shall be entitled to rebate for that time period for the added 5%. U 1358 FEC C2310230 11/CE/92 15 : 4£ $0 .00 2/003 ORD164A F 031 _ 1 ',It's x111- EEL:EPSTEIN CI:ER1 & EECOLL*0 V.FID CO , CO 941078 RE: ORDINANCE 11164-A PAGE 3 If any section, subsection, paragraph, sentence, clause, or phrase of this Ordinance is for any reason held or decided to be unconstitutional, such decision shall not affect the validity of the remaining portions hereof. The Board of County Commissioners hereby declares that it would have enacted this Ordinance in each and every section, subsection, paragraph, sentence, clause, and phrase thereof irrespective of the fact that any one or more sections, subsections, paragraphs, sentences, clauses, or phrases might be declared to be unconstitutional or invalid. The above and foregoing Ordinance Number 164-A was, on motion duly made and seconded, adopted by the following vote on the 26th day of October, A.D. , 1992. 11 �l /// BOARD OF COUNTY COMMISSIONERS ATTEST: met V/% WELD COUNTY, COLORADO Weld County Clerk to the Board „1/4,h-tat-6-,/...142 - (NAY) Geo e K nedy, Chairman `7 j BY: ( aN �1 q ��)? �L' AYE) Depl4jy clerk to„�.he Boa l Constance L. Harbert, Pro-Tem APPROV D *..TO ORM: k~ /' (AYE) n C. W. irb! (AYE) i County Attorney ac i/ (AYE) W. H. Webste Read and Approved: October 26, 1992 Publication: October 29, 1992 Effective: October 26, 1992 ORD164A B 13SF, PLC 6231C12C 11 /01/92 3E : 4E 40 . C ( 2 /CC3 F 0313 MAIN P.F.I' FLUEEST'EIN CLERK & FECCF (vL DEF. LL CC, CC 941078 DEVELOPMENT STANDARDS (CHANGES) 18 . The truck unloading pad shall be constructed of an impervious material and graded to insure that all spilled waste is contained within said truck unloading pad. 22 . Every load of liquid waste shall be scrutinized by the facility manager or other qualified and trained employee to assure that an approved liquid waste material is being received for disposal . 24 . The manager of the facility or other trained and qualified employee shall be knowledgeable with the approved Special Review permit conditions and Development Standards, be knowledgeable in operating the injection well, and be on site at all times that the facility is open for business to receive liquid wastes . EXHIBIT 941078 Hello